OSHA’s website is a great place to start, says John Oleachea, a Denver-based compliance assistance specialist in OSHA Region 8. “Under the A-to-Z index is an updated guidebook on how to set up an effective safety and health management program,” he notes. “It will take you step by step through the process of setting up a good safety and health program that includes things like management, commitment, and leadership, and how to incorporate the participation of workers into that program.”
Oleachea and Jim Johnston. senior safety and health consultant at the Utah Labor Commission’s Occupational Safety and Health Division, were joined by ISRI members during a Sept. 28 ISRI webinar about OSHA’s onsite consultation program.
“Because consultation is voluntary, you must request consultation services; that’s how it all begins,” Johnston explains. “Much unlike compliance, [OSHA] will not show up on your doorstep unless they’re invited.”
The rest of the process is straightforward:
- A consultant will discuss your specific needs and set up a visit date based on the priority assigned to your request, your work schedule, and the time needed for the consultant to adequately prepare to serve you.
- The consultant will start with an opening conference before beginning the walk-through.
- The consultant will study your entire workplace, pointing out safety or health risks (some of which may not have an applicable OSHA standard).
- After the walk-through, the consultant will review the findings with you before leaving.
- Finally, the consultant will send you a detailed written report explaining the findings and confirming any abatement periods agreed upon.
Trevor Beecher, safety engineer at Western Metals Recycling in Salt Lake City, explains how he was able to get OSHA to relax an initial site-visit recommendation to have every spring on a series of shaker tables guarded to keep workers’ fingers from getting crushed while moving materials onto a conveyor belt.
“I got chicken thighs to approximate human hands and chicken bones to approximate human fingers. Threw them in [rubber] gloves so it wasn’t spreading salmonella,” Beecher relates. “I took this and shoved it into the spring as it was running.”
Beecher supplied video evidence that the springs did not harm the chicken meat or bones. “I sent it off to consultation and said, ‘This really isn’t a pinching hazard.’ I get an email back that said, ‘This is the best thing I’ve ever seen. And you’re good.’”
Lisa Dunn, assistant general manager at Venice, Ill.-based Becker Iron & Metal, explained how the onsite consultation program is not the “Big Bad Wolf.” Rather, the consultants found and flagged everyday safety concerns that prompted the company to re-evaluate its safety approach.
“One of the greatest benefits that we received was the collaboration amongst our employees. We made it a true collaborative effort between employees, supervisors, and the owners,” she says. “Our safety committee evolved from this and has grown to be an integral part of our safety culture.”
Tony Smith, ISRI’s vice president of safety, notes senior leadership engagement with the process at Becker and Western Metals. “That is a huge step in getting this to work across the organization,” he says. “We want to prevent all incidents, accidents, serious injuries, fatalities—anything like that, that happens in [recycling] operations. Having that buy-in from senior leadership must be there to be successful.”
ISRI’s safety team will conduct a class, “Hazard Recognition, Fire Safety and Prevention in Recycling” , which will be taught Oct. 18-19 in Spanish and Oct. 20-21 English. OSHA helped pay for the class through the Susan Harwood training grant.
The fall ISEC will be virtual and spread over three Thursdays in November. Register here for the event.
