Federal safety regulators are making a list and checking it twice.
But this is no holiday list and you don’t want your company to be on it.
The U.S. Occupational Safety and Health Administration (OSHA) each year compiles a list of employers with elevated incident rates that the agency intends to inspect under its Site Specific Targeting Program (SST). OSHA identifies potential unsafe work locations using two oddly named measures - the Days Away Restricted Transfer Rate (DART) and “Days Away from Work Injury and Illness Rate” (DAFWII).
These lists have real consequences for Massachusetts employers now that OSHA is stepping up enforcement activity and moving away from cooperative compliance programs. The number of OSHA inspections has increased substantially during the past several years and assessed penalties are two to three times what they would have been three years ago. It is not uncommon for a small employer to be assessed a total penalty for $15,000-$20,000 for a half-dozen relatively minor violations.
How can you determine your risk of inspection?
If your DART or DAFWII rates exceed the following, and you were requested by OSHA to provide your 300A log information, you can expect an OSHA visit in 2012.
Manufacturing 7.0 5.0
Non-Manufacturing, Except Nursing & Personal Care 15.0 14.0
Nursing & Personal Care 16.0 13.0
DART Rate is computed by totaling all injuries and illnesses that result in lost time, restricted duty or job transfers and multiplying the number by 200,000 and dividing by the total number of hours worked. The DAFWII is calculated the same way using only cases that resulted in lost work time.
OSHA also plans to target specific hazards under National and Local Emphasis Programs. These inspections will focus on chemical exposures, lead, combustible dusts, hexavalent chrome, silica, amputations and other hazards.
Many employers still do not understand how OSHA operates, what the OSHA standards mean, or what their rights are when OSHA shows up at their door. Employers need to know the OSHA process, focus on correcting deficiencies, and reduce incident rates to avoid an inspection and costly penalties.
If you need some assistance to determine your inspection risk, please feel free to contact me at firstname.lastname@example.org. Better yet, look into the upcoming AIM OSHA/Safety Certificate series that I will be teaching in May. It’s a great way to begin improving your safety program and compliance activities.
Tom Crupi is Vice President of Loss Control at A.I.M. Mutual Insurance Company in Burlington.