Changes to OSHA's Field Operations Manual

Effective March 26, 2009, OSHA released the revised Field Operations Manual. This manual contains OSHA's general enforcement policy and procedures for use by the agency's field officers. The officers use this manual while conducting inspections, issuing citations, and proposing penalties. The major changes can be found in section VII and include:

• Program Planning
  
• Inspection Procedures
  
• Violations
  
• Case File Preparation and Documentation
  
• Penalties and Debt Collection
  
• Post-Citation Procedures and Abatement Verification
  
• Settlements
  
• Complaint and Referral Processing
  
• Industry Sectors
  
• Imminent Danger, Fatality, Catastrophe And Emergency Response
  
• Specialized Inspection Procedures
  
• Federal Agency Safety And Health Programs
  
• Health Inspection Enforcement Policy
  
• Legal Issues
  
• Disclosure Under The Freedom of Information Act (FOIA)
  

Along with the changes to the Field Operations Manual there will also be an increase in regulatory action by OSHA. Due to the American Recovery and Reinvestment Act of 2009, signed into law by President Obama on February 17th, 2009, hundreds of billions of federal dollars will be distributed to employers across the country for various growth projects. OSHA will be directing their enforcement efforts to areas that have received stimulus package-related funding. It is estimated that OSHA will be adding an additional 250 inspectors to its workforce with $6.5 million used for enforcement efforts. The new administration is pro-enforcement and will be making inspections a priority. The increase of inspections means an increase of fines and citations.

States with state plans that did not accept stimulus package money, such as Indiana, will continue to be governed by their state OSHA. It is unknown what the future holds for these states and exactly how much jurisdiction the federal government will have. Currently the United States Department of Labor has a targeting list and would like to see states follow it. As of right now, states that have state plans that did not accept the stimulus money do not have to follow the targeting list. The inspectors in states like Indiana will be following their regular inspection list and will add the additions from the targeting list as necessary.

It is more important than ever to have a proactive safety program in place and to follow it. Make sure employees understand the program and actively participate. Ensure all employees have the proper training and keep it well documented. Make sure all employee documentation is readily available upon request. A special focus should be placed on your OSHA 300-log and forms for recording work-related injuries and illnesses. OSHA is putting an emphasis on these documents to ensure employers are using them properly.

There will be many more changes with the new administration for employee health and safety. Some major areas of focus for OSHA in the next twenty-four months include:

• Combustible dust
  
• Cranes
  
• Diacetyl
  
  
  
  
  

Steps of Ladder Safety

Workplace fatalities topped 5000 in 2008. 680 were results of falls, a 20% decline from 2007. Though a 20% decline was recorded, falls still accounted for almost 14% of all workplace fatalities. The primary cause of these deaths was falls from ladders. Ladder safety is often an overlooked topic in the workplace. Here are some safe work tips when working around ladders:

1. Read and follow all of the manufactures labels and markings on the ladder.
   
2. Inspect all ladders prior to use. Any damage, manipulation, or missing parts must be noted. All ladders found damaged must be taken out of service. Something as simple as drilling a hole in the top of a ladder to set a tool is considered a damaged ladder, and must no longer be used. First, it affects the ladders ability to function to its specifications. Second, it is a sure way to be cited by OSHA.
   
3. Never use an "A-Frame" ladder when it is folded up.
   
4. Assure all locks on an extension ladder are in place.
   
5. Never put a ladder on top of another object.
   
6. Ladders should be erected on the ground with stable footing.
   
7. Straight ladders should be anchored to prevent tipping.
   
8. Ladders should extend at least 3 1/2 feet above the landing area.
   
9. Never stand on top of a ladder.
   
10. Never move or shift a ladder when a person or equipment is on the ladder.
    
11. Never lean over, reach, or stretch while on a ladder.
12. Should you need to reach, climb to the bottom and reset the ladder.
    
13. Ladders must be kept free of oil, grease, and other slipping hazards.
    
14. Maintain at least 3 points of contact with a ladder at all times - 2 feet and 1 hand or 2 hands and 1 foot.
    
15. The base of a ladder should be at least 1 foot away from the wall for every 4 feet in vertical distance the ladder is extended.
    

Observing these common steps in ladder safety will prevent injury and ensure a safe workforce.