OSHA INSPECTION DATA ON POTENTIAL IH ISSUES

 

During the period October 1999 to September 2000, the Federal Occupational Safety and Health Administration (OSHA) conducted almost 25,000 workplace inspections resulting in almost 110,000 citations valued at over $83 million¹. Not surprisingly, 1910.1200, Hazard Communication, continues to rank as the most frequently cited standard with proposed penalties over $1.5 million. Although there is a great deal of variation in job duties among industrial hygienists, the information and comments below summarize inspection data for OSHA General Industry standards industrial hygienists are likely to address during the course of their work:

 

 

Like any data, caution should be used concerning the conclusions you reach after reviewing the data. The following general comments are offered for one perspective on the data provided:

 

*      Overall, the total number of Federal OSHA Inspections (8542) for potential IH issues suggests an average of 23 inspections per day (assuming inspections every day of the year including National Holidays) in the 26 states that Federal OSHA has jurisdiction. On the surface, this might suggest a low likelihood of Inspection when you consider the number of businesses regulated in those 26 states.

*      The average $ penalty per citation and inspection would appear to be low ($577 and $1295 respectively) potentially suggesting that the threat of penalties is minor compared to the cost of an inspection by a private consultant (or attorney fees in defense of proposed citations). This, however, neglects the possibility of inspections that address multiple standards. This data also reflects the median workplace which may or may not be representative of your workplace.

*      This data does indicate Hazard Communication Inspections occur over twice as often as the second most cited standard (1910.134 Respiratory Protection).

*      The data on Process Safety Management (1910.119) indicates that although few inspections occur annually, Federal OSHA considers the violations of that standard serious with proposed penalties almost 10 times higher than the average citation. In my opinion, this is as it should be since failures with those highly hazardous materials can produce serious losses.  This data would suggest that businesses that use highly hazardous materials may need additional work to comply with the Process Safety Management standard.

*      A comparison of data between Noise and General Air Contaminants (1910.95 and 1910.1000) indicates more attention to Noise with almost four times as many Noise inspections than General Air Contaminant inspections. However, when you consider all air contaminant inspections including those for specific chemical standards (Lead, Formaldehyde, etc.), the total number of air contaminant inspections exceeds the number of Noise inspections by about 23%. This would suggest a slightly higher emphasis on air contaminant standards with specific emphasis on the substance specific standards.

 

This data has been provided for your review and is not intended as a critical review of the efforts by Federal OSHA to meet the legislative mandate to protect the health and safety of the Nation’s work force.  Although you may have reached the conclusion that the hammer of enforcement is not all that heavy when it comes to potential IH issues, this would be inaccurate since the potential still exists for penalties in excess of the average.  There are many other good reasons for investing in a safe and healthful workplace free of chemical and physical hazards that could cripple and kill precious human resources. Please contact me to discuss an assessment of workplace IH issues that may have an impact on the success of your business!

 

 

 

¹ Source – Federal OSHA Inspection Data on Most Frequently Cited Standards for All SIC codes for the period October-1999 to September 2000. The figures reported in the opening paragraph include data for General Industry, Construction, and Maritime inspections for the period reported. Dollar figures have been rounded and reflect penalties updated as of 010411. Data on this page does not presently reflect State Plan inspection data. Visit www.osha.gov to review the raw data.