By Greg Collins, Industrial Safety Administrator for the OSHA On-Site Consultation Program
Small employers in northeast Ohio now have the option to avoid an OSHA inspection after self-reporting injuries to OSHA under a new recordkeeping rule. This rule requires employers to report to OSHA any work-related fatalities within eight hours, and to report to OSHA all work-related inpatient hospitalizations, all amputations, and all losses of an eye within 24 hours.
Under a pilot program, the OSHA Area Office in Cleveland will offer these small employers the opportunity to work with Ohio’s OSHA On-Site Consultation Program instead of undergoing an OSHA inspection. This approach to improving safety and health is known as Rapid Response Investigation, or RRI.
Depending upon the severity of the incident, employers who report to OSHA about injuries will receive a letter that asks them to:
- Conduct an incident investigation,
- Provide documentation of hazard abatement,
- Document findings and corrective actions taken which should be posted in the workplace,
- Provide a certificate of posting, and
- Schedule a visit with BWC’s OSHA On-Site Consultation Program.
The employer must respond to OSHA within five days of receipt of the initial letter. Working with the OSHA On-Site Consultation Program is voluntary. If the employer chooses not to work with the consultation program, it may be inspected by OSHA. However, if the employer does not provide an adequate response to the letter, it will be inspected by OSHA.
The OSHA On-Site Consultation Program will consider these requests for services as high priority requests. The goal for response time by the consultation program is 14 days or less.
The services offered by the OSHA On-Site Consultation Program will be exactly as they have always been. The only differences from our normal operating procedures are as follows:
- We are making these requests for service high priority for receiving our services.
- We are starting off with a limited service visit, focusing only on the incident(s) that caused the employer to report themselves to OSHA.
- We are offering to expand the scope of the visit if desired by the customer.
- We are going to help with incident investigations.
In addition to RRI requests for service, the OSHA On-Site Consultation Program may also respond to requests from employers where OSHA has received certain employee complaints.
This arrangement is a pilot plan, starting August 1st and going to September 30th. If it is successful, it may be expanded to the other three OSHA Area Offices in Ohio, or beyond.
For more information see Year One of OSHA’s Severe Injury Reporting Program: An Impact Evaluation.