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Introduction to OSHA
INSTRUCTOR GUIDE
OSHA Directorate of Training and Education
April 2011
Table of Contents
TRAINER PREPARATION GUIDANCE
Lesson Overview
Topic 1: Why is OSHA important to you?
- History of OSHA
- OSHA's mission
- Importance of this training
Topic 2. What rights do you have under OSHA?
- Right to a safe & healthful workplace
- Right to know about hazardous chemicals
- Right to information about injuries and illnesses in your workplace
- Right to complain or request hazard correction from your employer
- Right to training
- Right to hazardous exposure records and medical records
- Right to file a complaint with OSHA
- Right to participate in an OSHA inspection
- Right to be free from retaliation for exercising safety and health
rights
- Worker responsibilities
Topic 3. What responsibilities does your employer have under OSHA?
- Provide a workplace free from recognized hazards & comply with
OSHA standards
- Provide training required by OSHA standards
- Keep records of injuries and illnesses
- Provide medical exams and access to exposure and medical records
- Not discriminate against workers who exercise their rights
- Post OSHA citations and abatement verification notices
- Provide and pay for PPE
Topic 4. What do the OSHA standards say?
- Types of standards
- How the standards are organized
Topic 5. How are OSHA inspections conducted?
- Inspection priorities
- Stages of an inspection
- Citations and penalties
- Appeals process
Topic 6. Where can you go for help?
- Sources within the workplace/worksite
- Sources outside the workplace/worksite
- How to file an OSHA complaint
Session Summary
Conduct Test - Answer Key
References
APPENDIX A: MSDS Explanation
APPENDIX B: Handout #12a, #12b, #12c Answer Sheet
APPENDIX C: Check Yourself Test Questions Answer Sheet
APPENDIX D: Check Yourself Test Questions Student Copy
TRAINER PREPARATION
GUIDANCE
The Introduction to OSHA lesson of the Outreach Training
Program includes an instructor guide for the trainer, a slide presentation,
and student handouts. This lesson is for General Industry, Construction
and/or Maritime Industry training.
Using the Instructor Guide (IG): The IG consists of instructions
for trainer preparation, a detailed lesson plan, instructor references
for student Handouts #3 and #12a, #12b, and #12c, along with test questions
and answers. The IG contains detailed content, activities, references
and notes for the trainer. It is not intended to be a script that
is read verbatim to the students. Rather, trainers should review the entire
guide (including referenced materials and internet links) prior to conducting
training, and use it as a resource in their planning and presentation.
The instructor presentation and preparation materials not included in
this package may be downloaded from the OSHA
website. The OSHA standards may also be purchased from the Government
Printing Office (GPO) Bookstore.
The learning objectives: The Introduction to OSHA lesson
was developed based on the terminal (TO) and enabling objectives (EO)
below. These objectives are the expected student outcomes; therefore,
the trainer may not vary from these objectives when planning the training
session.
TO: Given OSHA historical events and current information,
the student will be able to explain the importance of OSHA in providing
a safe and healthful workplace to workers covered by OSHA.
Specifically, the student will be able to:
EO 1: Explain why OSHA is important to workers
EO 2: Explain worker rights under OSHA
EO 3: Discuss employer responsibilities under OSHA
EO 4: Discuss the use of OSHA standards
EO 5: Explain how OSHA inspections are conducted
EO 6: Utilize helpful worker safety and health resources
Using the Slide Presentation: The
Microsoft PowerPoint TM 2003 file consists of 48 slides, which may be
used by the trainer as a visual aid during the session. However, the focus
of the training should be on discussion and interaction with the students,
not on the PowerPoint TM slides. The presentation was developed using
Microsoft PowerPoint
TM 2003; therefore, it is compatible with this and higher versions of
the product.
Using the Student Handout Packet: The packet contains
12 numbered handouts representing 16 files in the packet, since there
are 3 versions (one for General Industry, one for Construction and one
for Maritime) of 2 of the handouts (Handout #8, How to Read the OSHA Standards
and Handout #12, Filing an OSHA Complaint). Along with your copy, copies
of the Student Handout Packet should be made for each student.
An overview of the handouts and their use are tabled below. Step-by-step
instructions are contained in the IG in the Detailed Content and Notes
sections of the lesson.
Handout |
Use |
#1. Weekly Fatality/Catastrophe
Report |
Topic 1: Use during
the Fatality/Catastrophe Small Group Activity. You may also download
a Fatality/Catastrophe list of weekly reports from the OSHA website. |
#2. OSHA Poster |
Topic 2: Discuss the
worker rights included on the poster, as well as additional worker
rights. |
#3. MSDS Example |
Topic 2: Conduct a
group discussion on MSDSs and chemicals used in the workplace. Appendix
A, MSDS Explanation, may be used for instructor reference. |
#4. Your Rights as
a Whistleblower Fact Sheet |
Topic 2: Highlight
when covering the worker right to be free from retaliation for exercising
safety and health rights. |
#5. Refusing to Work
Because Conditions are Dangerous |
Topic 2: Refer to
when covering the worker right to refuse to do a job if the worker
believes in good faith that they are exposed to an imminent danger. |
#6. OSHA 300 Log example
|
Topic 3: Use when
conducting the OSHA-300 Log Classroom Exercise. |
#7. Employers Must
Provide and Pay for PPE |
Topic 3: Discuss when
covering the employer requirement to provide and pay for PPE. |
#8. How to Read the
OSHA Standards: a. General Industry; b.
Construction; c. Maritime Industry |
Topic 4: Use when
conducting the OSHA Standards Classroom Exercise. Select the version
(a, b or c) which is appropriate for your audience. |
#9. Safety and Health
Resources |
Topic 6: Refer to
when discussing safety and health resources outside the workplace/worksite. |
#10. Navigating the
OSHA Website |
Topic 6: Discuss when
covering the OSHA website. |
#11. Identifying Safety
and Health Problems in the Workplace |
Topic 6: Refer to
when discussing filing a complaint to get workplace hazards corrected. |
#12. Filing an OSHA
Complaint includes tips for completion, scenario and form: a.
General Industry*; b. Construction*; c.
Maritime Industry* |
Topic 6: Highlight
when conducting the Filing an OSHA Complaint Small Group Activity.
Select the version (a, b or c) which is appropriate for your audience.
Appendix B, Handout #12a, #12b, #12c Answer Sheet, may be used for
instructor reference. |
*You may develop an alternate scenario for the activity
covering filing a complaint (Handout #12a, #12b, or #12c). If so, the
following information should be included:
- Company name, address and telephone number (and site information,
if a different location)
- Management official in charge
- Type of business
- Description of the hazard or hazards, including location and number
of workers exposed
- Whether the hazard has been brought to the attention of management
or other government agency
For the alternate scenario, you can use a situation
with which you are familiar, or you can access OSHA
accident summaries for scenario ideas.
Media and/or Teaching Methods
The "Introduction to OSHA" 2-hour session has been set up as a facilitated,
interactive training session.Students are given small "chunks" of information,
and then are able to test their understanding of the subject matter via
activities and workshops. Several practice sessions included are designed
to increase student awareness and enable them to apply what they have
learned when they return to their workplaces.
Ideal Setting or Conditions for the Training Session
The ideal setting for this course is a classroom or other area where students
have space to break into groups.
Disclaimer
This material is intended for training purposes only. Its purpose is to
provide basic information about OSHA to workers and to inform workers
of their rights under OSHA. This material is not a substitute for any
provision of the Occupational Safety and Health Administration or any
standards issued by OSHA.
Lesson
Overview
The purpose of this two-hour lesson is to provide workers with introductory
information about OSHA. This Instructor Guide is intended to be used when
presenting General Industry, Construction, and/or Maritime Industry outreach
courses. The lesson is comprised of the following six topics:
- Why is OSHA important to you?
- What rights do you have under OSHA?
- What responsibilities does your employer have under OSHA?
- What do the OSHA standards say?
- How are OSHA inspections conducted?
- Where can you go for help?
The lesson provides basic knowledge of: OSHA's history
and mission, worker rights under OSHA, employer responsibilities under
OSHA, OSHA standards, OSHA inspections, and safety and health resources,
including how to file an OSHA complaint.
![Materials Needed Materials Needed](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/materials.png)
Materials
Needed:
Listed in presentation order
- Flip chart and markers
- Presentation slides
- Student handout package
- OSH Act
- Copy of the OSHA Standards, General Industry, Construction,
or Maritime
- Check Yourself Test Questions
|
![Training Preparation Training Preparation](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/training.png)
Training
Preparation:
- All About OSHA publication
- Complaint scenario [Handouts #12a, #12b, and #12c] answers
- Cornell University Library site on the Triangle
Fire
- MSDS explanation
- NIOSH
website
- OSHA website
- State Job Safety and Health Programs Fact Sheet
- Training Requirements in OSHA Standards and Training Guidelines
publication
|
![Student Handout Packet Student Handout Packet](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/handouts.png)
Student
Handout Packet:
- Weekly Fatality/Catastrophe Report
- OSHA Poster
- MSDS Example
- Your Rights as a Whistleblower Fact Sheet
- Refusing to Work Because Conditions are Dangerous
- OSHA 300 Log example
- Employers Must Provide and Pay for PPE
- How to Read the OSHA Standards:
- General Industry;
- Construction;
- Maritime Industry
- Safety and Health Resources
- Navigating the OSHA Website
- Identifying Safety and Health Problems in the Workplace
- Filing an OSHA Complaint includes tips for completion, scenario
and form:
- General Industry;
- Construction,
- Maritime Industry
|
Topic 1: Why
is OSHA important to you?
- History of OSHA
- OSHA's mission
- Importance of this training
Instruction for Topic 1:
- Ask the class "Questions to Ask" and discuss.
- Conduct Small Group Activity: Weekly Fatality/Catastrophe Report
as an introduction to the training session. See page 2 (below).
- Discuss "Detailed Content" section.
- Conduct the Classroom Exercise OSHA Coverage. See page 5.
- Have the class answer the Questions for Review.
Questions to Ask:
- When, during your work experience, did you first hear about
OSHA?
- What did you think about OSHA then?
- What do you think OSHA's job is?
|
NOTES: |
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/small_group.png)
Small Group Activity
Fatality/Catastrophe (FAT/CAT) Report
Have the class break up into groups of 3-5
people.
- Refer students to the Weekly Fatality/Catastrophe Report and
explain its purpose. (Emphasize that this represents one week
of worker fatalities reported to OSHA.) Show where the current
report is located on the website, if available.
- Tell the class to look at the list and see if they know or
have heard of any similar incidents or
near misses. Allow a minute or so for the class to scan the report.
- Ask each group to discuss an incident from the report, or a
similar incident that they know of or have heard about on their
job.
- After a few minutes, bring class back together.
- Ask for a few volunteers to share an experience they may have
heard of, what they discussed in their group, and how an incident
was or may have been prevented.
|
Refer to Handout #1: Weekly
Fatality/Catastrophe Report and/or Fatality/Catastrophe list of weekly
reports online.
http://www.osha.gov/dep/fatcat/dep_fatcat.html |
Sum
up the exercise by stating that hazard prevention is OSHA's priority.
If workers know their rights, and employers meet their responsibilities,
lives and limbs can be saved. Focus on how important this training
is to the participants. |
Detailed Content for Topic 1:
A. History of OSHA
OSHA stands for the Occupational Safety and Health Administration,
an agency of the U.S. Department of Labor. OSHA's responsibility is
worker safety and health protection. The U.S. Congress created OSHA
under the Occupational Safety and Health Act of 1970 (the OSH Act).
Congress passed the law and established OSHA "to assure so far as
possible every working man and woman in the nation safe and healthful
working conditions and to preserve our human resources."
OSHA began because, until 1970, there were no national laws for safety
and health hazards. |
|
Some events that led to the OSHA law
include:
- The 1911 Triangle Shirtwaist Company fire in New York City killed
146 of 500 employees in one of the worst work-related disasters
in our country's history. Factory workers, mainly young, female
immigrants working long hours for low wages, died because doors
were locked and there were no fire escapes. This tragedy outraged
the public, who called for safety and health reform. Frances Perkins,
who later became the first Secretary of Labor, investigated the
Triangle fire and tried to find ways to prevent future occurrences.
- Production for World War I caused a crisis in workplace safety
and health conditions. The government created a Working Conditions
Service to help states inspect plants and reduce hazards.
- In the 1930's, as part of President Roosevelt's New Deal, additional
laws increased the federal
government's role in job safety and health. But the federal role
was mainly to provide service and
information to state governments. By the late1950's, the Federal-State
partnership could no longer deal with the growing workforce and
increasing hazards. Additional federal laws were enacted, but
only covered certain industries.
- By the 1960's, 14,000 workers died every year and more than
2.2 million workers were not able to work from injuries and illnesses.
|
If
Internet access is available, and time permits, briefly explore the
Cornell University Library web exhibit on the Triangle
Fire (http://www.ilr.cornell.edu/trianglefire/) with the class.
There are also videos about the fire on YouTube.com |
Many thought that the only solution was a Federal
law with the same rules and enforcement for everyone. On December
29, 1970, President Nixon signed the OSH Act. This Act created OSHA,
the agency, which formally came into being on April 28, 1971. With
the creation of OSHA, for the first time, all employers in the United
States had the legal responsibility to provide a safe and healthful
workplace for employees. And, there were now uniform regulations that
applied to all workplaces. |
Ask the class if anyone has seen the OSH Act. Tell them that they
can find it on OSHA's website. Show them the website, if internet
access is available, or have a hard copy of the Act to show them.
|
The OSH Act is also known as Public Law 91-596. It covers all private
sector employers and their workers in the 50 states and all territories
and jurisdictions under federal authority. Employers and workers
in many fields, including but not limited to manufacturing, construction,
longshoring, agriculture, law, medicine, charity and disaster relief
are covered by OSHA. Religious groups are covered if they employ
workers for secular purposes, such as maintenance or gardening.
Which groups do not come under OSHA's coverage?
- The self-employed;
- Immediate members of farming families not employing outside
workers;
- Mine workers, certain truckers and transportation workers,
and atomic energy workers who are covered by other federal agencies;
- Public employees in state and local governments, although some
states have their own plans that cover these workers.
|
The OSH Act covers Federal workers by conducting inspections in response
to complaints, but OSHA cannot propose monetary fines against federal
agencies. |
Classroom Exercise
OSHA Coverage
Covered
by
OSHA? |
Worker |
YES NO |
1. Harry Adams,
a miner at Below Ground Inc. |
YES NO |
2. Adrian Smith,
one of 3 employees of ABC landscaping. |
YES NO |
3. Taylor Dell,
an accountant in business for herself. |
YES NO |
4. Rob Jones,
one of 10 carpenters working for Woody, Inc. |
|
Ask the class the questions on coverage and discuss the responses.
Answers:
- No, miners are covered by MSHA;
- Yes.
- No, the self-employed are not covered.
- Yes.
|
B. OSHA's mission
Now that you know a little bit about why OSHA was created, let's
talk about OSHA's mission. The mission of OSHA is to save lives,
prevent injuries and protect the health of America's workers.
To achieve this, federal and state governments work together with
more than 100 million working men and women and eight million employers.
Some of the things OSHA does to carry out its mission are:
- developing job safety and health standards and enforcing them
through worksite inspections,
- maintaining a reporting and recordkeeping system to keep track
of job-related injuries and illnesses, and
- providing training programs to increase knowledge about occupational
safety and health.
|
|
OSHA also assists the States in their efforts to
assure safe and healthful working conditions, through OSHA approved
job safety and health programs operated by individual states. State
plans are OSHA-approved job safety and health programs operated by
individual states instead of federal OSHA. States with approved plans
cover most private sector employees as well as state and local government
workers in the state. State plan programs respond to accidents and
employee complaints and conduct unannounced inspections, just like
federal OSHA. And, some states have OSHA-approved plans that cover
only state and local government workers. |
Refer
to the OSHA website for additional information on State Programs and
a State Plan directory.
If you are conducting training in a location with state jurisdiction,
discuss the Federal/State relationship in more detail. Refer to the
State Job Safety & Health Programs Fact Sheet for additional information. |
C. Importance of this training
Even though OSHA has had an impact on worker safety and health,
significant hazards and unsafe conditions still exist in U.S. workplaces.
Each year:
- On average, 15 workers die every day from job injuries
- Over 5,600 Americans die from workplace injuries annually
- Over 4 million non-fatal workplace injuries and illnesses were
reported; and
The estimated cost of occupational injuries and
illnesses are from $145 billion to $290 billion a year for direct
and indirect costs
OSHA is a small agency, with approximately 1000 federal inspectors
and 1400 state inspectors to cover about eight million workplaces.
As you can see from these numbers, OSHA cannot be everywhere. That
is why it is important for you to know your rights and for employers
to be aware of their responsibilities under OSHA. This training
will help you know whether your employer is complying with OSHA
standards, what rights you have related to job safety and health,
and where you can go if you need help.
When you know your rights, and when employers act responsibly to
prevent hazards, the result will be fewer worker deaths, injuries
and illnesses. Training and education are key in making this happen. |
During discussion of OSHA's impact and what remains to be done, re-emphasize
the fatalities reported to OSHA in a one week timeframe from the Small
Group Activity conducted earlier.
Figures are from the AFL-CIO Report, Death on the Job: The Toll
of Neglect, April, 2009. According to the report, "these estimates
are based upon only injuries that are disabling and that are reported
by employers, and understate the full extent of occupational injuries
and illnesses and their associated costs." |
Questions for Review
- Why was OSHA necessary?
- What is OSHA's mission?
- Why is this training important?
|
Answers:
- Workplace injuries, illnesses and death were increasing
and no uniform or comprehensive law existed to protect against
workplace hazards.
- To save lives, prevent injuries and protect the health
of America's workers.
- You'll know your rights, if there are hazards in your workplace,
and where to get help.
|
Topic 2.
What rights do you have under OSHA?
- Right to a safe and healthful workplace
- Right to know about hazardous chemicals
- Right to information about injuries and illnesses in your workplace
- Right to complain or request hazard correction from employer
- Right to training
- Right to hazard exposure and medical records
- Right to file a complaint with OSHA
- Right to participate in an OSHA inspection
- Right to be free from retaliation for exercising safety and
health rights
- Worker responsibilities
|
|
Instruction for Topic 2:
- Refer to the OSHA Poster and discuss the worker rights
included. Note that there are additional rights that will be discussed
in this session.
- Discuss "Detailed Content" section.
- Conduct Classroom Exercise on the Material Safety Data Sheet
(MSDS). See page 9.
- Have the class answer the Questions for Review.
|
Refer to Handout #2: Copy of OSHA Poster |
Detailed Content for Topic 2
The Occupational Safety and Health Act of 1970 gave workers many new
rights related to safety and health. OSHA standards which have been
issued since then, such as the Hazard Communication or "Right to Know"
standard, provide additional right. |
|
A. Right to a safe &
healthful workplace
Most importantly, the creation of OSHA provided workers the right
to a safe and healthful workplace. Section 5(a)(1) of the OSH Act
states: "Each employer shall furnish to each of his employees employment
and a place of employment which are free from recognized hazards that
are causing or are likely to cause death or serious physical harm
to his employees." A safe and healthful workplace means
that hazards are removed and workers are trained. If a hazard cannot
be removed completely, protection (for example, respirators or earplugs)
must be provided.
Some examples of a safe/healthful workplace include:
- Fall protection and training are provided and required when
working at high levels on a construction site.
- Machines and equipment with rotating and moving parts are guarded.
|
Ask the class if they have seen the OSHA poster in their workplace.
If so, ask where it is posted. |
Tell
the class that all employers covered by the OSHA Act must display
the OSHA poster. (Employers in states operating OSHA-approved state
plans should obtain and post the state's equivalent poster.)
|
Ask the class to provide examples of how a safe and healthful workplace
is provided [or should be provided] at their workplace or worksite. |
If not discussed, provide additional examples,
such as:
- Trenches are inspected and have protective systems in place.
- Proper confined space entry procedures, testing, equipment,
and training are present.
- Noise levels are controlled. When levels are still high, workers
are given hearing tests and are provided training and hearing
protection.
- Protection from chemical hazards is provided, including an
evaluation of chemicals used, a written program, Material Safety
Data Sheets, worker protection (for example, respirators or gloves),
and information and training.
B. Right to know about hazardous chemicals
Another important right is the Right to Know about hazardous substances
in your workplace. Employers must have a written, complete hazard
communication program that includes information on:
- Container labeling,
- Material Safety Data Sheets (MSDSs), and
- Worker training. The training must include the physical and
health hazards of the chemicals and how workers can protect themselves;
including specific procedures the employer has implemented to
protect workers, such as work practices, emergency procedures,
and personal protective equipment.
The program must also include a list of the hazardous
chemicals in each work area and the means the employer uses to inform
workers of the hazards of non-routine tasks. In addition, the program
must explain how the employer will inform other employers of hazards
to which their workers may be exposed (for example, contract workers).
|
|
Classroom Exercise
MSDS
- Refer to the MSDS example and, using the MSDS explanation for
reference, have a brief group discussion on MSDSs and chemicals.
Some questions to start the discussion include:
- What information does the MSDS provide?
- Has anyone seen an MSDS in their workplace?
- Were the instructions on the MSDS followed in their workplace?
- Has anyone worked with hazardous substances without an
MSDS?
|
Refer
to Handout #3: MSDS Example for student. Use Appendix A:
MSDS Explanation if needed. |
Sum
up the exercise by emphasizing that the MSDS provides important information
to workers about hazardous chemicals in the workplace. |
C. Right to information about
injuries and illnesses in your workplace
OSHA's Recordkeeping rule requires most employers with more than 10
workers to keep a log of injuries and illnesses. The log, which is
also called the OSHA 300, must contain all work-related injuries and
illnesses resulting in lost workdays, restricted work or transfer
to another job, as well as any incident requiring more than first
aid treatment.
You have the right to review the current log, as well as the logs
stored for the past 5 years. The employer must provide this by the
end of the next workday. The names and other information on the log
may not be removed, unless the case is a "privacy concern case."
You also have the right to view the annually posted summary of the
injuries and illnesses (OSHA 300A). |
Ask the class if their employer has set up a way for them to report
injuries and illnesses. |
The
right to review the log includes former employees, their personal
representatives, and authorized employee representatives.
"Privacy concern cases" are those involving an intimate body part,
mental illness, HIV, etc. For more detail, see 1904.29(b)(7). |
D. Right to complain or request
hazard correction from your employer
Workers may bring up safety and health concerns in the workplace to
their employers without fear of discharge or discrimination, as long
as the complaint is made in good faith. OSHA regulations [29CFR 1977.9(c)]
protect workers who complain to their employer about unsafe or unhealthful
conditions in the workplace. You cannot be transferred, denied a raise,
have your hours reduced, be fired, or punished in any other way because
you have exercised any right afforded to you under the OSH Act.
Since you are often closest to potential safety and health hazards,
you have a vested interest in reporting problems so that the employer
gets them fixed. If the hazard is not getting corrected, you should
then contact OSHA. |
Ask the class if they have ever reported a hazard to
their supervisor. If so, what was the outcome? |
1977.9(c)
states: "the principles of the Act would be seriously undermined if
employees were discouraged from lodging complaints about occupational
safety and health matters with their employers. Such complaints to
employers, if made in good faith, therefore would be related to the
Act, and an employee would be protected against discharge or discrimination
caused by a complaint to the employer." |
E. Right to training
You have a right to get training from your employer on a variety of
health and safety hazards and standards that your employer must follow.
We're already discussed the training required under OSHA's Hazard
Communication (Right to Know) standard. Other required training includes
lockout-tagout, bloodborne pathogens, noise, confined spaces, fall
hazards in construction, personal protective equipment, and a variety
of other subjects. |
|
F. Right to hazardous exposure records
and medical records
Under OSHA's standard 1910.1020, you have the right to examine and
copy exposure and medical records, including records of workplace
monitoring or measuring a toxic substance. This is important if
you have been exposed to toxic substances or harmful physical agents
in the workplace, as this regulation may help you detect, prevent,
and treat occupational disease.
Examples of toxic substances and harmful physical agents are:
- Metals and dusts, such as, lead, cadmium, and silica.
- Biological agents, such as bacteria, viruses, and fungi.
- Physical stress, such as noise, heat, cold, vibration, repetitive
motion, and ionizing and
non-ionizing radiation.
OSHA standards require employers to measure exposure
to harmful substances, and workers or their representatives have
the right to observe the testing and examine the results. If the
exposure levels are above the limit set by the standard, the employer
must tell workers what will be done to reduce their exposure.
|
Access
means the right to examine and copy medical and exposure records. |
G. Right to file a complaint with OSHA
You may file a complaint with OSHA if you believe a violation of a
safety or health standard, or an imminent danger situation, exists
in your workplace. You may request that your name not be revealed
to your employer. You can file a complaint on OSHA's web site, in
writing or by telephone to the nearest OSHA area office. You may also
call the office and speak with an OSHA compliance officer about a
hazard, violation, or the process for filing a complaint.
If you file a complaint, you have the right to find out OSHA's action
on the complaint and request a review if an inspection is not made.
|
Filing
a complaint is covered later in this session. |
H. Right to participate in an OSHA inspection
If an OSHA inspection is conducted in your workplace, you have the
right to have your representative accompany the inspector on the inspection.
You also have the right to talk to the inspector privately. You may
point out hazards, describe injuries, illnesses or near misses that
resulted from those hazards and describe any concern you have about
a safety or health issue. You also have the right to find out about
inspection results and abatement measures, and get
involved in any meetings or hearings related to the inspection. You
may also object to the date set for the violation to be corrected
and be notified if the employer files a contest. |
CONTEST:
If an employer disagrees with the results of the OSHA inspection,
he or she may submit a written objection to OSHA, called a Notice
of Contest. |
I. Right to be free from retaliation for exercising safety
and health rights
Workers have a right to seek safety and health on the job without
fear of punishment. That right is spelled out in Section 11(c) of
the OSH Act. The law says the employer shall not punish or discriminate
against employees for exercising such rights as complaining to the
employer, union, OSHA, or any other government agency about job
safety and health hazards. Workers are also protected for participation
in OSHA inspections, conferences, hearings, and other OSHA-related
activities. Workers also have the right to refuse to do a job if
they believe in good faith that they are exposed to an imminent
danger. "Good faith" means that even if an imminent danger is not
found to exist, the worker had reasonable grounds to believe that
it did exist. Since the conditions necessary to justify a work refusal
are very stringent, refusing work should be an action taken as a
last resort. If time permits, the condition should be reported to
OSHA or
the appropriate government agency.
If you believe you have been punished for exercising your safety
and health rights, you must contact OSHA within 30 days.
J. Worker responsibilities
OSHA holds employers responsible for the safety and health conditions
in the workplace and does not cite workers for violations. However,
Section 5(b) of the OSHA Act states that each employee shall comply
with occupational safety and health standards and all applicable
rules, regulations and orders. Workers are encouraged to follow
all appropriate safety and health rules, and wear protective equipment
while working. |
Refer to Handout #4: Your Rights as a Whistleblower
Fact Sheet Refer to Handout #5:
Refusing to Work because Conditions are Dangerous |
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/question.png)
Questions for Review
- What does an MSDS tell you?
- What are some worker rights related to injury and illness reporting?
- Name some standards or hazards where workers must be trained.
|
Answers:
- Chemical name, hazardous ingredients, physical and chemical
characteristics, fire and explosion hazards, compatibility and
reactivity, health hazards, precautions for safe use and handling,
and control measures.
- Know how to report injuries/illnesses, see the annual summary,
review the log.
- Lockout/Tagout, fall hazards in construction, hazard communication,
confined spaces, bloodborne pathogens, and personal protective
equipment.
|
Topic 3. What
responsibilities does your employer have under OSHA?
- Provide a workplace free from recognized hazards and comply
with OSHA standards
- Provide training required by OSHA standards
- Keep records of injuries and illnesses
- Set up a reporting system
- Provide copies of logs, upon request
- Post the annual summary
- Report within 8 hours any accident resulting in a fatality
or the hospitalization of 3 or more workers
- Provide medical exams when required by OSHA standards and provide
workers access to their exposure and medical records
- Not discriminate against workers who exercise their rights
under the Act (Section 11(c))
- Post OSHA citations and abatement verification notices
- Provide and pay for PPE
Instruction for Topic 3:
- Discuss "Detailed Content" section.
- Ask the class about safety and health training they have received
on the job.
- Conduct the Classroom Exercise on the OSHA 300 Log. See page
20.
- Have the class answer the Questions for Review.
Detailed Content for Topic 3:
A. Provide a workplace free from recognized
hazards and comply with OSHA standards
Establishing a safe and healthful workplace requires every employer
to make safety and health a priority. In general, OSHA requires
employers to:
- Maintain conditions and adopt practices reasonably necessary
to protect workers on the job. The first and best strategy is
to control the hazard at its source. Engineering controls do this,
unlike other controls that generally focus on the worker who is
exposed to the hazard. The basic concept behind engineering controls
is that, to the extent feasible, the work environment and the
job itself should be designed to eliminate hazards or reduce exposure
to hazards.
- Be familiar with the standards that apply to their workplaces,
and comply with these standards.
- Ensure that workers are provided with, and use, personal protective
equipment, when needed.
[When exposure to hazards cannot be engineered completely out
of normal operations or maintenance work, and when safe work practices
and other forms of administrative controls cannot provide sufficient
additional protection, an additional method of control is the
use of protective clothing or equipment. This is collectively
called personal protective equipment, or PPE. PPE may also be
appropriate for controlling hazards while engineering and work
practice controls are being installed.], and
- Comply with the OSH Act's "General Duty Clause" where no specific
standards apply. [The general
duty clause, or Section 5(a)(1) of the Act requires each employer
to "furnish a place of employment
which is free from recognized hazards that are causing or are
likely to cause death or serious
physical harm to employees."]
|
|
B. Provide training required by OSHA
standards
We already discussed your right to receive training from your employer
on a variety of health and safety hazards and standards, such as
chemical right to know, fall protection, confined spaces and personal
protective equipment.
|
See the publication, Training Requirements in OSHA Standards and Training
Guidelines for additional information. |
Many OSHA standards specifically require the employer
to train workers in the safety and health aspects of their jobs. Other
OSHA standards make it the employer's responsibility to limit certain
job assignments to those who are "certified," "competent," or "qualified"-meaning
that they have had special previous training, in or out of the workplace.
OSHA believes that training is an essential part of protecting workers
from injuries and illnesses. |
Ask
the class about safety and health training they have received prior
to this course. |
OSHA construction standards include a general training
requirement, which states: |
See 1926.21(b) |
"The employer shall instruct each employee in
the recognition and avoidance of unsafe conditions and the regulations
applicable to his work environment to control or eliminate any hazards
or other exposure to illness or injury."
Additional general training requirements for construction include
training for workers:
- required to handle or use poisons, caustics, and other harmful
substances;
- who may be exposed to job sites where harmful plants or animals
are present;
- required to handle or use flammable liquids, gases, or toxic
materials; or
- required to enter into confined or enclosed spaces.
|
|
There are also more specific training requirements,
particularly in standards put into effect since 1990. For example,
OSHA's scaffold standard and fall protection standard each has a separate
section on training requirements that is intended to clarify the general
training requirements in 1926.21(b)(2). |
See
1926.454(a) and 1926.503(a) OSHA construction standards for scaffolds
and fall protection. |
The scaffold requirement says that employers shall
have each employee who performs work while on a scaffold trained by
a person qualified in the subject matter to recognize the hazards
associated with the type of scaffold being used and to understand
the procedures to control or minimize those hazards. It goes into
detail about what the training must cover. The fall protection standard
has similar requirements. |
|
OSHA's Hazard Communication standard applies
to both General Industry and Construction workers and requires that
employers provide workers with effective information and training
on hazardous chemicals in their work area at the time of their initial
assignment, and whenever a new physical or health hazard is introduced.
In addition, as we discussed earlier, chemical-specific information
must always be
available through labels and material safety data sheets (MSDSs).
OSHA requires the use of personal protective equipment (PPE) to
reduce employee exposure to hazards when engineering and administrative
controls are not feasible or effective in reducing these exposures
to acceptable levels. Employers are required to determine if PPE
should be used to protect their workers.
If PPE is to be used, a PPE program should be implemented. This
program should address the hazards present; the selection, maintenance,
and use of PPE; the training of employees; and monitoring of the
program to ensure its ongoing effectiveness. 1910.132(f) (which
applies to General Industry workplaces) contains detailed training
requirements for workers who must wear or use PPE.
|
See
1910.1200(h), OSHA standard for Hazard Communication information and
training. |
C. Keep records of injuries and illnesses
Including:
- Set up a reporting system
- Provide copies of logs, upon request
- Post the annual summary
- Report within 8 hours any accident resulting in a fatality
or the hospitalization of 3 or more workers
Recordkeeping is an important part of an employer's
responsibilities. Keeping records allows OSHA to collect survey
material, helps OSHA identify highhazard industries, and informs
you, the worker, about the injuries and illnesses in your workplace.
About 1.5 million employers with 11 or more employees-20 percent
of the establishments OSHA covers-must keep records of work-related
injuries and illnesses.
Workplaces in low-hazard industries such as retail, service, finance,
insurance, and real estate are exempt from recordkeeping requirements.
|
Employers
exempt from recordkeeping requirements must still report deaths and
the hospitalization of 3 or more to OSHA. |
Reporting
and Recording Checklist |
Employers
must:
- Report each worker death
- Report each incident that hospitalizes 3 or more workers
- Maintain injury & illness records
- Inform workers how to report an injury or illness to
the employer
- Make records available to workers
- Allow OSHA access to records
- Post annual summary of injuries & illnesses
|
For specific information on exactly which cases
must be recorded, you can go to Title 29 of the Code of Federal
Regulations (CFR) Part 1904-"Recording and Reporting Occupational
Injuries and Illnesses." The forms your employer must keep are:
- The Log of Work-Related Injuries and Illnesses (commonly called
the OSHA 300 Log) is used to list injuries and illnesses and track
days away from work, restricted, or transferred.
- The Injury and Illness Report (Form 301) is used to record
more information about each case. Employers can use a workers'
compensation or insurance form, if it contains the same information.
- The Summary (OSHA Form 300A) shows the totals for the year
in each category. A company
executive must certify that he or she has examined the OSHA Log
and believes that the annual summary is correct and complete.
The summary must be posted from February 1 to April 30 of each
year in a place where notices to workers are usually posted, such
as an employee bulletin board.
|
|
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/training.png)
Classroom Exercise OSHA
300 Log |
|
- Refer to the completed OSHA 300 Log example and emphasize that
this form provides the following information about the workplace:
- How many workers are getting injured or ill
- The types of injuries and illnesses reported
- The jobs and departments where the most severe injuries
or illnesses are occurring
- Point out where the following information can be located on
the OSHA-300:
- Employee's name: Column (B) - Note that employers cannot
remove names
- Job Title: Column (C) - Can show the most dangerous jobs
- Where the event occurred: Column (E) - Can show the most
hazardous departments
- Describe the injury or illness, parts of body affected,
and object/substance that directly
injured or made person ill: Column (F) - Can show the types
of injuries/illnesses and
how people are getting sick or hurt
- Page totals for Columns (G), (H), (I), & (J) - Shows
the total number of injuries and illnesses occurring
|
Refer
to Handout #6: OSHA 300 Log example |
Sum
up the exercise by emphasizing that it is important that OSHA injury
and illness records be correctly maintained. Also, workers have a
right to see the OSHA 300 Log and the posted OSHA 300A Summary.
|
D. Provide medical exams when required
by OSHA standards and provide workers access to their exposure and
medical records
We discussed access to medical records earlier when covering worker
rights. When you are working with chemicals or other hazardous substances,
your employer may be required to conduct monitoring or provide medical
examinations that involve you. An example of this would be if you
are working with lead, such as removing or stripping substantial quantities
of lead-based paints on large bridges and other structures. Plumbers,
welders, and painters are among those workers most exposed to lead.
Your employer must give you copies of medical or exposure records
involving you if you request them. |
|
E. Not discriminate against workers who
exercise their rights under the Act (Section 11(c))
|
|
Section 11(c) of the Act prohibits your employer
from discharging or in any manner retaliating against you or any worker
for exercising your rights under the Act. We've covered many of your
rights under OSHA earlier. Can you recall some of them? Depending
upon the circumstances of the case, "discrimination" can
include: firing or laying off; demoting; denying overtime or promotion;
disciplining; reducing pay or hours, and other actions. If you believe
your employer has discriminated against you because you exercised
your safety and health rights, contact your local OSHA Office right
away. The OSH Act gives you only 30 days to report discrimination. |
Ask
the class to recall some of their rights under OSHA. Rights include:
right to a workplace free of hazards, receiving training, access to
injury/illness and medical records, complaining to your employer or
OSHA about a safety and health problem, participating in an OSHA inspection,
and participating or testifying in any proceeding related to an OSHA
inspection.
OSHA also administers the whistleblower provisions of 17 other statutes,
protecting workers who report violations of various trucking, airline,
nuclear power and environmental laws. |
F. Post OSHA citations and abatement verification
notices
|
|
An OSHA citation informs the employer and workers
of the standards violated, the length of time set for correction,
and proposed penalties resulting from an OSHA inspection. Your employer
must post a copy of each citation at or near places where the violations
occurred for 3 days, or until the violation is fixed (whichever is
longer). Employers also have to inform workers of what they have done
to fix the violation, allow workers to examine and copy abatement
documents sent to OSHA, and tag cited movable equipment to warn workers
of the hazard. |
See
Abatement Verification Regulation, 1903.19, for additional information. |
G. Provide and pay for PPE
|
|
As we mentioned earlier, OSHA requires the use
of personal protective equipment (PPE) to reduce employee exposure
to hazards when engineering and administrative controls are not feasible
or effective in reducing these exposures to acceptable levels.
Employers are required to determine if PPE should be used to protect
their workers. OSHA also requires that employers pay for most required
PPE, except for uniforms, items worn to keep clean, weather-related
gear, logging boots, and non-specialty safety toe protective footwear
(including steel-toe shoes or steeltoe boots) and non-specialty prescription
safety eyewear, as long as the employer permits the items to be worn
off the job-site. |
Refer
to Handout #7: Employers Must Provide and Pay for PPE
Ask
the class if anyone wears personal protective equipment on their job
and discuss the requirement for employers to provide and pay for PPE.
The Employer Payment for Personal Protective Equipment rule was effective
on February 13, 2008 and had to be implemented by May 15, 2008. |
Examples of PPE that employers must pay
for include:
- Metatarsal foot protection,
- Rubber boots with steel toes,
- Non-prescription eye protection,
- Prescription eyewear inserts/lenses for full face respirators,
- Goggles and face shields,
- Fire fighting PPE (helmet, gloves, boots, proximity suits,
full gear),
- Hard hat,
- Hearing protection, and
- Welding PPE.
|
|
Questions for Review
- What are some of the responsibilities employers have related
to OSHA recordkeeping?
- Which section of the OSH Act prohibits employers from discriminating
against workers for exercising their safety and health rights?
- What are some types of PPE that employers must pay for?
|
Answers:
- Employers must set up a reporting system and inform workers
of how to report, maintain an OSHA-300 log and make it available
to workers, post the annual summary and report fatalities and
the hospitalization of 3 or more workers to OSHA.
- Section 11(c)
- Hardhats, hearing protection, etc.
|
Topic 4. What
do the OSHA standards say?
- Types of standards
- How the standards are organized
Instruction for Topic 4:
- Discuss "Detailed Content" section.
- Conduct the Classroom Exercise on how to read the OSHA Standards.
See page 25.
- Have the class answer the Questions for Review.
|
|
Detailed Content for Topic
4:
A. Types of standards
Now, let's talk briefly about the OSHA standards. OSHA standards fall
into four categories: General Industry, Construction, Maritime, and
Agriculture. |
Discuss/Show:
Copy of the OSHA standards book (General
Industry or Construction) |
OSHA issues standards for a wide variety of
workplace hazards, including:
- Toxic substances,
- Electrical hazards,
- Fall hazards,
- Hazardous waste,
- Machine hazards,
- Infectious diseases,
- Fire and explosion hazards, and
- Dangerous atmospheres.
In addition, as we discussed previously, where
there are no specific OSHA standards, employers must comply with
the OSH Act's "general duty clause." The General Duty
Clause, Section 5(a)(1), requires that each employer "furnish
... a place of employment which [is] free from recognized hazards
that are causing or are likely to cause death or serious physical
harm to his employees. |
General
Duty Clause violations cited by OSHA can be found on OSHA's website
at: http://www.osha.gov/oshstats/index.html. You can query by Hazard
Category, such as Crushing, Chemical or Guarding to locate actual
violations cited. One example, from a search using "Crushing," is:
"An employee was exposed to crushing hazards when a scissor lift rolled
down a ramp, pinning him against a backhoe while he was attempting
to move the lift off a flatbed. Emergency procedures such as chocking
were not followed." |
B. How the standards are organized
OSHA standards appear in the Code of Federal Regulations (CFR).
The OSHA standards are broken down into Parts. Part 1910 is known
as the General Industry Standards. Some of the types of industries
covered by the General Industry standards are manufacturing, the
service sector, and health care. Part 1926 covers the Construction
industry. Parts 1915, 1917 and 1918 are Maritime Industry standards.
|
|
Discuss the following:
- The CFR is divided into Titles. OSHA's standards are in Title
29.
- Under each Part, such as Part 1926, major blocks of information
are broken into subparts. For example, Subpart C is named General
Safety and Health Provisions. Subpart C contains sections 1926.20
through 1926.35.
- All OSHA standards are available on OSHA's website. You can
look them up by the standard number or do a search by topic.
|
If
time permits and Internet access is available, show the class how
to locate OSHA standards online. You may also wish to show the class
how to locate the Most Frequently Cited (MFC) Standards online at:
http://www.osha.gov/pls/imis/citedstandard.html
Note: From the MFC website, to search SIC, use C for Construction
or D for Manufacturing, Maritime SICs include 373 and 449. |
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/training.png)
Classroom Exercise
OSHA Standard |
|
- Ask the class to briefly look at "How to Read the OSHA Standards"
handout.
- Ask the class the questions on the standards and discuss the
responses.
|
Refer to Handout #8a, #8b or #8c: Use #8a for General
Industry; Use #8b for Construction; Use #8c for Maritime Industry |
Questions
For General Industry:
- What is the Subpart for Personal Protective Equipment?
- What is the Subpart for Machinery and Machine Guarding?
- What topic does 1910, Subpart H cover?
For Construction:
- What is the Subpart for Fall Protection?
- What is the Subpart for Fire Protection and Prevention?
- What topic does 1926, Subpart K cover?
For Maritime Industry:
- What is the 29 CFR 1915 Subpart for Tools and Related Equipment?
- What is the 29 CFR 1917 Subpart for Personal Protection?
- What topic does 29 CFR 1918, Subpart H cover?
|
Standards Answers:
General Industry:
- Subpart I
- Subpart O
- Hazardous Materials in General Industry
Construction:
- Subpart M
- Subpart F
- Electrical Standards in Construction
Maritime Industry:
- Subpart H
- Subpart E
- Handling Cargo
|
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/question.png)
Questions for Review
- What are the OSHA Construction standards also called?
- What are the General Industry standards also called?
- What are 29 CFR Parts 1915, 1917 and 1918 referred to as?
|
Answers:
- Part 1926
- Part 1910
- Maritime Industry Standards
|
Topic
5. How are OSHA inspections conducted?
- Inspection priorities
- Stages of an inspection
- Citations and penalties
- Appeals process
Instruction for Topic 5:
- Discuss "Detailed Content" section.
- Ask the class if anyone has been at work during an OSHA inspection.
If so, ask them to briefly share their experience.
- Have the class answer the Questions for Review.
Detailed Content for Topic 5:
A. Inspection priorities
The OSH Act authorizes OSHA compliance safety
and health officers (CSHOs) to conduct workplace inspections at
reasonable times. OSHA conducts inspections without advance notice,
except in rare circumstances (for example, when there is a report
of an Imminent Danger). In fact, anyone who tells an employer about
an OSHA inspection in advance can receive fines and a jail term.
Since not all eight million worksites covered by OSHA can be inspected,
the agency has a system of inspection priorities.
Priority |
Category
of Inspection |
1st
|
Imminent
Danger |
2nd |
Fatality/Catastrophe |
3rd |
Complaints/Referrals |
4th |
Programmed
Inspections |
|
|
1st. Imminent Danger has top priority. This is
a condition where there is reasonable certainty a danger exists
that can be expected to cause death or serious physical harm immediately
(or before the danger can be removed through normal enforcement).
An example could be workers working in an unstable trench that has
no shoring or sloping. In such cases, OSHA may contact the employer
and try to have workers removed from the danger right away. In any
case, a CSHO will make an inspection, no later than one day after
the report was received.
2nd. Fatalities and Catastrophes are next in priority.
As we learned earlier, employers must report to OSHA any worker
fatality or the hospitalization of three or more employees. OSHA
starts these investigations as soon as possible after getting the
report. CSHOs gather evidence and interview the employer, workers,
and others to determine the causes of the event and whether violations
occurred.
3rd. Complaints and Referrals are OSHA's third
priority. A worker or worker representative can file a complaint
about a safety or health hazard in the workplace. Generally, it
is necessary for the complaint to be written and signed for OSHA
to conduct an inspection. In other cases, OSHA may contact the employer
by phone, email or fax. Referrals usually are from a government
agency, such as NIOSH or a local health department. They are handled
the same way as complaints.
4th. Programmed Inspections are the fourth priority.
These inspections cover industries and employers with high injury
and illness rates, specific hazards, or other exposures. There may
also be special emphasis programs in just one OSHA region or certain
area offices, based on knowledge of local industry hazards.
OSHA also conducts Follow-up and Monitoring Inspections.
These inspections are made as needed, and take priority over Programmed
Inspections. A follow-up is made to see if violations cited on an
earlier inspection were fixed. Monitoring inspections are made to
make sure hazards are being corrected and workers are protected
whenever a long period of time is needed for a hazard to be fixed.
B. Stages of an inspection
There are four major stages of an OSHA inspection: Presenting Credentials;
the Opening Conference; the Walkaround; and the Closing Conference.
1. Presenting Credentials
When arriving at the workplace, the CSHO finds out who
is in charge and presents his or her credentials. An employer can
require OSHA to get a warrant before an inspection is made.
2. Opening Conference
The CSHO finds out if workers are represented and, if so, makes
sure that the worker representative participates in all phases of
the inspection. If the employer or worker representative objects
to a joint conference, separate conferences are held.
Selecting
worker representatives |
IF |
THEN |
Workers
are represented by a recognized bargaining representative
|
The
union usually designates the worker representative to accompany
the CSHO |
There
is a plant safety committee and no recognized bargaining representative |
The
worker members of that committee or the workers at large will
designate the worker representative |
There
is neither a recognized bargaining representative nor a plant
safety committee |
The
workers themselves may select their representative, or the
CSHO will determine if any other worker would be suitable
to be a representative |
There
is no authorized worker representative |
The
CSHO must consult with a reasonable number of workers concerning
safety and health matters in the workplace |
The opening conference is generally brief so
that the CSHO may quickly start the walkaround. In the opening conference,
the CSHO:
- Explains why OSHA selected the worksite for inspection;
- Obtains information about the company, including a copy of
the hazard assessment to see what personal protective equipment
is necessary;
- Explains the purpose of the visit, the scope of the inspection,
walkaround procedures, worker representation, private worker interviews,
and the closing conference; and
- Determines whether the facility falls under any inspection
exemption through a voluntary compliance program (for example,
if an OSHA-funded consultation visit is in progress).
At the start of the inspection, the CSHO checks
the injury and illness records. The CSHO also checks that the OSHA
poster is displayed and that the OSHA Summary of Injuries and Illnesses
is posted from February 1 to April 30 each year. Other records related
to safety and health issues may be requested.
3. The Walkaround
After the opening conference, the CSHO, along with the employer
and worker representatives, proceed through the workplace, inspecting
work areas for potentially hazardous working conditions. Apparent
violations are brought to the attention of employer and worker representatives
as the CSHO observes and documents them. The CSHO may also interview
workers, take photographs or video, and monitor worker exposure
to noise, air contaminants, or other substances. The CSHO will conduct
all worker interviews in private, although workers may request that
a union representative be present.
4. Closing Conference
After the walkaround, the CSHO holds a closing conference with the
employer and the worker representatives, either jointly or separately.
When the employer does not want to have a joint conference, the
CSHO will normally hold the conference with the worker representative
first, so that worker input is received before employers are informed
of proposed citations. During the closing conference, apparent violations
that have been observed on the walkaround and estimated times for
correction are discussed. Employers are informed of their rights
and responsibilities related to the inspection. Both employer and
worker representatives are told of their rights to take part in
any future meetings and their contest rights. No citations are given
out at this time. They are sent in the mail at a later date (no
later than 6 months after the inspection).
C. Citations and penalties
The CSHO takes the findings back to the office and writes up a report.
The Area Director reviews it and makes the final decision about
the citations and penalties. Citations inform the employer and workers
of:
- Regulations and standards the employer allegedly violated;
- Any hazardous working conditions covered by the OSH Act's General
Duty Clause;
- The proposed length of time set for abatement of hazards; and
- Any proposed penalties.
Citations are sent by certified mail to the facility.
The employer must post a copy of each citation at or near the place
the violation occurred for 3 days or until it is fixed. Employers
must also inform workers and their representatives of the correction
they make. |
|
Penalties are based on violation type. OSHA
may cite the following violations and propose the following penalties:
VIOLATION
TYPE |
PENALTY |
WILLFUL
A violation that the employer intentionally and knowingly commits
or a violation that the employer commits with plain indifference
to the law. |
OSHA may propose penalties of up to $70,000 for each willful
violation, with a minimum penalty of $5,000 for each willful
violation.
|
SERIOUS
A violation where there is substantial probability that death
or serious physical harm could result and that the employer
knew, or should have known, of the hazard. |
There is a mandatory penalty for serious violations which may
be up to $7,000. |
OTHER-THAN-SERIOUS
A violation that has a direct relationship to safety and health,
but probably would not cause death or serious physical harm.
|
OSHA may propose a penalty of up to $7,000 for each other-than-serious
violation. |
REPEATED
A violation that is the same or similar to a previous violation.
|
OSHA may propose penalties of up to $70,000 for each repeated
violation. |
OSHA may also assess penalties to employers for
the following:
- Failure to Abate. OSHA may propose an additional
penalty of up to $7,000 for each day an employer fails to correct
a previously cited violation beyond the required date.
- Falsifying Information. Under the OSH Act,
an employer providing false information to OSHA can receive a
fine of up to $10,000 or up to 6 months in jail, or both.
- Violation of Posting. The employer has to
post citations and abatement verification for three days or until
the hazard is corrected. The posting has to be near the violation
or at a central location. Failure to follow these instructions
can result in a penalty of up to $7,000 for each violation. OSHA
may adjust a penalty downward depending on the gravity of the
violation, the employer's good faith (efforts to comply with the
Act), history of previous violations, and size of business.
|
Criminal
Willful violations, which involve the death of a worker, may have
a penalty of up to $250,000 for an individual and $500,000 for an
organization, or by up to 6 months in jail.
Ask the class if they can think of an example of:
- a serious violation. (An example would be not providing guarding
or fall protection for workers on a 25 foot scaffold. The resulting
fall would most likely result in death, broken bones and/or other
serious injuries.)
- an "other-than-serious" violation. (An example of this type
of violation could be an area with poor housekeeping, creating
a tripping hazard. The most likely result would be abrasions or
bruises. However, this would only be the case if there were no
sharp objects, broken glass, etc. in the area.),
|
D. Appeals process
Employers and workers each have rights to disagree with (or appeal)
parts of an OSHA citation. Workers and their representatives may
request an informal conference with OSHA to discuss the inspection,
citations, penalties or a notice of contest (if filed by the employer).
Workers may also contest the abatement time for any violation and
an employer's petition for modification of abatement (PMA), but
they cannot contest citations or penalties. If you, as a worker,
plan to contest an abatement time, you should provide information
to support your position. The employer has more rights than workers
related to citations. Employers may request an informal conference
with OSHA to discuss the case. They can also reach a settlement
agreement with OSHA that adjusts citations and penalties in order
to avoid prolonged legal disputes. If an employer decides to contest
the citation, the abatement date, and/or the proposed penalty, this
must be done, in writing, within the 15-working day contest period.
The area director forwards the notice of contest to the Occupational
Safety and Health Review Commission (OSHRC). An administrative law
judge decides the case.
Both workers and the employer have the right to participate in
the hearing and request a further review of the judge's decision
by the commission. |
Employers
have the right to request an extension of time for an abatement
date if they cannot meet the time stated on the citation for a cited
item. This is called a petition for modification of abatement, or
PMA
If a violation or abatement date is contested by the employer,
the situation does not have to be fixed until there is a final legal
order. If only the penalty is contested, the violation must be fixed
by the date in the citation. |
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/question.png)
Questions for Review
- Give an example of a reason why OSHA would conduct an inspection
at your workplace.
- What are the types of OSHA violations?
|
Answers:
- If a worker files a complaint, if there is a fatality,
if there is an imminent danger situation, etc.
- Willful, serious, other-thanserious, repeated and Criminal/Willful.
|
Topic
6. Where can you go for help?
- Sources within the workplace/worksite
- Sources outside the workplace/worksite
- How to file an OSHA complaint
Instruction for Topic 6:
- Discuss "Detailed Content" section.
- Conduct Small Group Activity: Completing an OSHA Complaint.
See page 40.
- Have the class answer the Questions for Review
Detailed Content for Topic 6:
A. Sources within the workplace/worksite
There are many resources available to you if you want to find out
more information about a safety or health issue in your workplace.
Some sources are:
- Employer or supervisor, co-workers and union representatives
- OSHA encourages workers and employers to work together
to reduce hazards. If possible, you should discuss safety and
health problems with your employer. You can also talk over your
concerns with other workers or your union representatives (if
there is a union).
- Material Safety Data Sheet (MSDS) for information on
chemicals - Earlier in this session, we talked about
the Material Safety Data Sheet, also called an MSDS, and what
information it supplies. If you are working with a chemical, the
MSDS can give you important information about its hazards and
the precautions and personal protective equipment needed to work
safely with it.
- Labels and warning signs - Labels and signs
can show hazard information to workers and can be useful in providing
additional information and making you aware of a potential safety
or health hazard. However, signs are not intended to take the
place of actual hazard correction. For example, a "Danger" sign
on an unguarded piece of machinery does not meet OSHA requirements
because the hazard is still present. OSHA standards such as those
for hazard communication, egress, confined space and Bloodborne
Pathogens require labels and signs. The employer must make sure
that each sign or label posted can be understood by all workers,
so the signs must be bilingual if workers do not understand or
read English.
- Employee orientation manuals or other training materials
- Orientation manuals and training materials about your
job should include information about how to work safely. As we
discussed earlier in this session, employers are required to provide
training to workers exposed to certain hazards, including chemicals,
falls, and confined spaces. All manuals and training materials
should be written clearly and spell out what you need to know
about your job hazards. They can also serve as a resource if you
have questions or concerns at a later date.
- Work tasks and procedures instruction - A
written job or task instruction can provide information about
the proper and safe way to perform a job. OSHA considers some
jobs and tasks very hazardous, such as locking out machinery,
and requires employers to have written procedures. If you have
questions about a new job or task, or a job or task that has changed,
be sure to ask for the written procedures and for additional training
on them.
|
|
B. Sources outside the workplace/worksite
If you cannot find out the safety and health information you need
in your workplace, there are many resources available outside the
workplace. |
Refer to Handout #9: Safety & Health Resources
|
- OSHA website: http://www.osha.gov and OSHA offices
If you have internet access, you will find that
the OSHA website has a lot of safety and health
information and links to resources that can help you.
For example, from the Home Page, you can:
- Find information in Spanish from the OSHA en Español
page,
- Locate Fact Sheets and QuickCards by going to the Publications
page.
- OSHA Fact Sheets provide basic background information on
safety and health hazards, and
- QuickCards are small, laminated cards that provide brief,
plain language safety and health information for workers.
For example, there are QuickCards on fall hazards, carbon
monoxide, and pneumatic nail gun safety.
|
Refer
to Handout #10: Navigating the OSHA Website
OSHA website: http://www.osha.gov;
Show the links to OSHA en Español, Fact Sheets and QuickCards,
etc. If time permits, show how to conduct a search on a safety and
health topic or hazard. For example, if you put "Lead" in the Search
Box, you get results including the standards in General Industry
and Construction, as well as Safety and Health Topics pages and
a publication on lead exposure in construction. |
You can contact OSHA by calling or visiting your
local area or regional office for safety and health information or
to discuss filing a complaint. Compliance Assistance Specialists in
the area offices conduct many training sessions and have training
materials and information that can be useful. |
Locate
the appropriate OSHA area or regional office contact information for
your audience and provide it to the class. |
NIOSH is OSHA's sister agency, with a focus
on research and training. NIOSH can be a great resource for workers.
NIOSH also conducts Health Hazard Evaluations (HHEs) of workplaces
in cases where workers are getting sick from an unknown cause or
are exposed to an agent or working condition that is not regulated
by OSHA. A worker can request an HHE if he or she is currently an
employee at the workplace of concern and has the signatures of two
other workers.
Other resources that can help you get information on safety and
health concerns include: |
Show
the class the NIOSH website: www.cdc.gov/niosh |
- OTI Education Centers (OTIEC) and other University occupational
and environmental health programs. The OTIECs offer the most popular
OSHA courses and a variety of safety and health programs including
community outreach efforts, Spanish-language courses, and youth
initiatives.
- Doctors, nurses, and other health care providers can be a resource
on the health effects of toxic substances, proper medical and
first aid treatment, and other health-related issues. If you are
discussing a health concern with your health care provider, try
to provide them with as much information about the chemical or
substance as possible. For example, if you are getting headaches
at work, try to get the names and MSDSs or labels of the chemicals
to which you are exposed.
- Public libraries have books, journals and magazines on various
safety and health topics, as well as internet access.
- Other local, community-based resources, such as the National
Council for Occupational Safety and Health (COSH) and local COSH
groups in California, New England, the Northeast, the Midwest
and the South, can be a valuable resource. COSH organizations
around the U.S. are committed to promoting worker health and safety
through training, education, and
advocacy.
|
For additional information on OTI Education Centers, see http://www.osha.gov/dte/edcenters/index.html
For additional information on COSH groups, see: http://www.coshnetwork.org/
|
C. How to file an OSHA
complaint
If you, your co-workers and/or your union representative determine
that an OSHA inspection is needed to get workplace hazards corrected,
you have several options.
- You can download the complaint form from OSHA's website, complete
it and mail or fax it to OSHA. A written, signed complaint submitted
to the OSHA area or State Plan office is most likely to result
in an onsite inspection.
- You can file a complaint online. However, most online complaints
are handled by OSHA's phone/fax system, which means they are resolved
informally over the phone.
- You can telephone or visit your local regional or area office
to discuss your concerns. After the
discussion, OSHA staff can give or send you a complaint form if
you wish to file.
- Note that if a hazard is life-threatening, call the Regional
or local office or 1-800-321-OSHA
immediately.
|
A representative can also be an attorney or any
person acting in a bona fide representative capacity, such as clergy,
social workers, spouses, government officials and nonprofit groups.
Refer to Handout #11: Identifying Safety and Health
Problems in the Workplace
|
The
complaint will be evaluated by OSHA to determine if an inspection
will be conducted. For OSHA to conduct an inspection, there must be
reasonable grounds to believe that a violation of the OSH Act or an
OSHA standard exists. |
Completing the complaint form
Highlight the following about the complaint form prior to the Small
Group Activity:
- Be specific and include appropriate details: The information
on the complaint form may be the only description of the hazard
that the inspector will see before the inspection. The inspector
will base his or her research and planning on this information.
- Establishment Name, Address, & Type of Business: Be thorough
and specific. The inspector's research on the company and the
industry's hazards will be based on this information.
- Hazard Description/Location: The hazard description is the most
important part of the form. Your answer should explain the hazards
clearly. If your complaint is about chemicals, identify them whenever
possible and attach copies of labels or MSDSs if you can. Identify
the location so the inspector will know where to look.
- Has this condition been brought to the attention of the employer
or another government agency? You should indicate on the form
if you have tried to get the employer to fix the hazard before
filing the complaint. Also, if another agency, such as a local
fire or building department, has been notified of these hazards,
OSHA may want to consult with them.
- Do NOT reveal my name: OSHA will keep your name off the complaint,
if you wish. Remember that discrimination for health and safety
activity is illegal. If you are a union representative, you may
wish to have your name on the complaint.
- Signature and address: It is important to sign the complaint
if you want OSHA to conduct an onsite inspection. Also, your address
will allow OSHA to send copies of inspection related materials
to you.
|
|
Small Group Activity
Filing an OSHA Complaint
Have the students break into groups of 3-5 people.
- Refer to the Complaint form handouts which include the form,
tips for completing the form, and complaint scenarios.
- Have the class discuss the complaint scenario in their groups.
- Ask each group to determine what information would be important
to put on the complaint form and if any additional information
is needed. Use the complaint scenario answers as a reference.
- After a few minutes, bring class back together.
- Ask for volunteers to share the information their groups decided
was important and what other information should be added.
|
Refer
to Handout #12a, #12b, or #12c Filing an OSHA Complaint: Use
#12a for General Industry; Use #12b for Construction; Use #12c for
Maritime Industry
Explain to the students the handout consists of tips on completing
the form, the scenario specific to their industry, and the OSHA-7
Complaint form.
Sum up the activity by stressing that it is important to be specific
and accurate when completing an OSHA complaint, as this is the information
the CSHO will use to research, plan and begin the investigation. |
![Questions Questions](https://webarchive.library.unt.edu/web/20120927112504im_/https://www.osha.gov/dte/outreach/images/question.png)
Questions for Review
- What are some resources inside the workplace that will help
you find information on safety and
health issues?
- What are some resources outside the workplace that will help
you find information on safety and health issues?
|
Answers:
- Co-workers, union rep, supervisor, MSDS, labels, manuals,
etc.
- OSHA, NIOSH, Educational Centers, Community Organizations,
etc.
|
Session Summary
During this session, you have been introduced to basic information
about your safety and health at work. We have covered:
- The importance of OSHA, including the history of safety and
health regulation leading to the creation of OSHA and OSHA's mission;
- Worker rights under OSHA;
- Employer responsibilities;
- OSHA standards;
- OSHA inspections; and
- Safety and health resources, including how to file a complaint.
|
Ask the class if there is any material that needs to be covered in
more detail. |
Conduct Test - Answer Key
Distribute the "Introduction to OSHA - Check Yourself Test Questions."
Discuss the test answers with the class.
The following sessions will provide training on how you can recognize
specific hazards in your workplace or worksite.
Thank participants for their time, attention, and involvement in the session.
References:
- OSHA website and publications
- The Center for Construction Research and Training (CPWR); SMART MARK
the Sign of a Smarter Workplace, 8484 Georgia Avenue, Suite 1000, Silver
Spring, MD 20910
- The International Union of Operating Engineers (IUOE) National HAZMAT
training material
- The Labor Occupational Health Program of the University of California
booklets and guidance
- The National Institute of Environmental Health Sciences (NIEHS) curriculum
clearinghouse products
- The National Safety Education Center
- National Institute for Occupational Safety and Health (NIOSH) worker
training materials
- Service Employees International Union (SEIU) training materials
APPENDIX
A: MSDS Explanation
B: Handout #12a, #12b, #12c Answer Sheet
C:
Check Yourself Test Questions Answer Sheet
D:
Check Yourself Test Questions Student Copy
APPENDIX
A
MSDS EXPLANATION - USE WITH HANDOUT #3
MATERIAL SAFETY
DATA SHEET (MSDS) EXPLANATION
Material Safety Data Sheets (MSDS) should be available through your
supervisor. OSHA specifies the information that must be included in English
on an MSDS. MSDS formats will vary depending on the product's manufacturer.
Section
I
Chemical Identity |
The
chemical and common name(s) is provided for single chemical substances.
An identity on the MSDS must be cross-referenced to the identity found
on the label. |
Section
II
Hazardous Ingredients |
For
a chemical mixture that has been tested in whole to determine hazards,
the chemical and common names of ingredients that are associated with
the hazards, and the common name of the mixture are listed. If the
mixture has not been tested as a whole, the chemical and common names
of all ingredients determined to be health hazards and comprising
1% or greater of the composition are listed. Carcinogens must be listed
if they are present at levels of 0.1% or greater. |
Section
III
Physical and Chemical Characteristics |
The
physical and chemical characteristics of the product are listed. These
include facts such as boiling and freezing points, density, vapor
pressure, specific gravity, solubility, volatility, and the product's
general appearance and odor. |
Section
IV
Fire and Explosion Hazard Data |
The
compound's potential for fire and explosion is described. The fire
hazards of the chemical and conditions under which it could ignite
or explode are identified along with recommended extinguishing agents
and fire-fighting methods. |
Section
V
Reactivity Data |
Substances
that the chemical is not compatible with or reacts with are listed.
Information on any hazardous decomposition products, such as carbon
monoxide, is also included in this section. |
Section
VI
Health Hazards |
The
health hazards of the chemical, including signs and symptoms of exposure,
are listed. Medical conditions that may be aggravated by exposure
to the product are also listed. The route of entry, the primary pathway
by which the chemical enters the body, is provided. The four principal
routes of entry are: inhalation, ingestion, injection, and skin absorption.
MSDS also supplies exposure levels that are deemed unhealthful, as
determined by standards or recommended by the manufacturer. |
Section
VII
Precautions for Safe Handling and Use |
The
precautions for safe handling and use of the product along with procedures
for cleaning up spills are described. |
Section
VIII
Control Measures |
Any
applicable control measures for using the product, including engineering
controls, safe handling procedures, and personal protective equipment
are provided. |
APPENDIX
B
FILING AN OSHA COMPLAINT SCENARIO ACTIVITY - ANSWER SHEETS #12a, #12b,
AND #12c
#12a: General
Industry Complaint Scenario - Answer Sheet
Use the following scenario to determine what
information should be put on an OSHA complaint form. Is any additional
information needed?
Important information is bolded:
You have worked at Ben Brothers Woodworking for 8 years
as a janitor. Ben Brothers is located at 88 Wren Street, Anytown,
USA, 40001. The company makes and refinishes office furniture.
You usually work the second shift, but come in early sometimes.
You and at least 3 of your co-workers have been getting headaches
when you are working in the warehouse and the propane-operated forklift
is running. You have had headaches over the past two months, at least
twice a week.
The forklift operator told you that there are a lot of problems
with the forklift and it needs to be replaced. You reported your headaches
to your supervisor. She told you to go outside until you felt better and
that there was nothing more she could do. You did some research
and found out that exposure to propane in a confined, unventilated area
can cause headaches, dizziness, difficulty breathing and unconsciousness.
There is no monitoring of the air in the warehouse. There is no
union at the facility. You decide to file a complaint with OSHA.
Additional information needed:
Site phone; mailing address phone; Management Official in charge. Remind
participants that their contact information and signature are very important.
NOTES:
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
#12b: Construction
Complaint Scenario - Answer Sheet
Use the following scenario to determine what
information should be put on an OSHA complaint form. Is any additional
information needed?
Important information is bolded:
You are a construction worker for ABC, Inc, 1000 Sweet Road, Anytown,
USA, 40001. ABC does non-residential plumbing, heating
and airconditioning work. You have worked for ABC for 3 years.
You, along with 7 co-workers, have been installing sheetmetal
ductwork in the lower level of the Anytown Shopping Mall,
which is undergoing renovation, for the past few weeks. The site is located
in the Northwest quadrant, in the basement of the anchor store,
located at 555 Times Drive, in Anytown. One of your co-workers has been
operating a 65- horsepower concrete cutting saw in the same area. The
saw is being run in the propane mode. You and several co-workers get headaches
from the fumes whenever the saw is used and have told your supervisor
about the problem. The supervisor said that nothing could
be done, because the General Contractor, CAB Management, has control over
the site and this job will be complete in another month. You
did some research and found out that exposure to propane in a confined,
unventilated area can cause headaches, dizziness, difficulty breathing
and unconsciousness. There is no ventilation or monitoring of
the air in the area.
After talking to your union representative, you decide
to file a complaint with OSHA.
Additional information needed:
Site phone; mailing address phone; Management Official in charge. Remind
participants that their contact information and signature are very important.
NOTES:
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
#12c: Maritime
Industry Complaint Scenario - Answer Sheet
Use the following scenario to determine what
information should be put on an OSHA complaint form. Is any additional
information needed?
Important information is bolded:
You are a longshoreman who operates a propane-operated forklift
truck for ABC, Inc, 1000 Pier Street, Anytown, USA, 40001. ABC is involved
in terminal operations and warehousing. You have worked for ABC
for 3 years. For the past week, you have been transporting rolls
of coiled steel from a storage area to a different section of the longshoring
terminal, due to hurricane damage to another part of the terminal.
As a result, you have been working inside the terminal more than you usually
do. The area you are working in is somewhat confined and crowded
due to extra storage. You have noticed that you are getting headaches
and feeling dizzy. Two other co-workers working with you are also having
the same symptoms. You are concerned that the forklift needs maintenance,
and have asked your supervisor to have it checked out, but he looked it
over and said it didn't need service. You and your union representative
requested air monitoring of the area, but your supervisor did not agree.
There is limited ventilation in the area. You did some research
and found out that exposure to propane in a confined, unventilated area
can cause headaches, dizziness, difficulty breathing and unconsciousness.
After talking to your union representative, you decide
to file a complaint with OSHA.
Additional information needed:
Phone numbers; Management Official in charge. Remind participants that
their contact information and signature are very important.
NOTES:
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________
APPENDIX
C
CHECK YOURSELF TEST QUESTIONS - CORRECT ANSWER IS BOLD
Instructor Copy - answers
provided separately
APPENDIX
D
CHECK YOURSELF TEST QUESTIONS - STUDENT
- OSHA's mission is to:
- Protect the safety and health of the general public.
- Protect the safety and health of America's workers.
- Ensure that all workers receive the federal minimum wage.
- Ensure that all workers receive adequate workers' compensation
payments.
- The creation of OSHA provided this important right to workers:
- The right to equal employment opportunities.
- The right to privacy.
- The right to pension benefits.
- The right to a safe and healthful workplace.
- A Material Safety Data Sheet (MSDS) gives information about:
- Hazardous chemicals.
- Injuries in the workplace.
- Medical examinations.
- Machinery maintenance.
- Among the rights related to OSHA recordkeeping, workers have the right
to review:
- All first aid treatment forms.
- All Workers Compensation forms.
- The OSHA 300 Log and the OSHA 300A Summary.
- Medical and exposure records for all workers.
- During an OSHA inspection:
- Worker representatives are not permitted to accompany the inspector.
- You may not describe safety and health concerns you have to the
inspector.
- Employers determine which workers are interviewed.
- You have the right to talk to the inspector privately.
- The right of workers to seek safety and health on the job without
fear of punishment is spelled out in:
- State laws.
- The OSHA standards.
- Section 11(c) of the OSH Act.
- The General Duty Clause
- One of the main responsibilities employers have under OSHA is to:
- Provide training required by OSHA standards.
- Reduce air pollution in the environment.
- Conduct energy audits.
- Notify OSHA of any workplace injury or illness.
- OSHA requires that employers pay for most required personal protective
equipment (PPE), including:
- Uniforms.
- Logging boots.
- Hard hats.
- Weather-related gear.
- The OSHA standards for Construction and General Industry are also
known as:
- Part 1926 and Part 1910.
- Part 1915 and Part 1917.
- Codes 501 through 1000.
- Construction and GI Registers.
- What type of OSHA inspection is conducted when immediate death or
serious harm is likely?
- Complaint.
- Programmed.
- Referral.
- Imminent danger.
- When the employer receives an OSHA citation, it must be:
- Copied and mailed to each worker.
- Posted for 3 days or until the violation is fixed.
- Contested and filed with the courts.
- Signed and returned to OSHA.
- If you feel that an OSHA inspection is needed to get hazards corrected
at your workplace, which is your best option?
- File a complaint online.
- Submit a written, signed complaint with specific hazard information.
- Request a Health Hazard Evaluation from NIOSH.
- Submit an unsigned complaint form to OSHA.
|