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Tom Crupi

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Are You On OSHA's 'List' for 2012?

Posted by Tom Crupi on Feb 14, 2012 8:42:00 AM

Federal safety regulators are making a list and checking it twice.

SafetyBut 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.
                                                                                              DART          DAFWII
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 tcrupi@aimmutual.com. 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. 

Topics: OSHA, Regulation, Safety

OSHA Enforcement Push Underscores Value of Workplace Safety

Posted by Tom Crupi on Mar 30, 2010 3:59:00 PM

The U.S. Occupational Safety and Health Administration (OSHA) is going on the offensive.

OSHA's new assistant secretary, David Michaels, has made it clear that the agency will step up its enforcement actions against employers. The OSHA budget for Fiscal Year 2010 increased 10 percent and the agency plans to hire 100 compliance officers nationwide. Meanwhile, OSHA is de-emphasizing cooperative initiatives such as the Voluntary Protection Programs (VPP) and alliances promoted under the two previous assistant secretaries.

Region 1, which encompasses the New England States, will hire a dozen new compliance officers.  Regular inspections will be directed towards employers with an elevated Days Away Restricted Transfer or DART rate. DART is an accident/illness incident rate that OSHA uses to evaluate a company's safety performance. All injuries or illnesses that result in lost time, restricted duty or job transfer are counted and the total multiplied by 200,000 and divided by the number of hours worked.

OSHA also plans to target specific hazards under the National Emphasis Program (NEP).  NEP inspections will focus on chemical exposures, lead, combustible dusts, hexavalent chrome, silica, and others.  In addition, OSHA plans to conduct comprehensive record keeping inspections in an effort to catch employers who are underreporting injuries and illnesses.

Inspection activity has already increased in Massachusetts, and penalties are at higher levels than they were several years ago.  The acceleration in enforcement is the most significant I have seen in my 40 years of helping companies develop health and safety programs. 

When I teach the AIM OSHA/Safety Certificate series,  I find that many employers do not fully understand  the OSHA standards, nor what their rights are when OSHA shows up at their door.  Employers need to become familiar with how OSHA operates, focus on correcting deficiencies, and reducing their DART rate.  If not, they will be at risk for an inspection and costly penalties.

Tom Crupi is Vice President of Loss Control for A.I.M. Mutual Insurance Company, a workers compensation insurance company based in Burlington

Topics: A.I.M. Mutual Insurance Company, Workplace Safety, AIM

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