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OSHA Checklist for General Industry

Quick Tips #113
Introduction

A 1999 survey by OSHA revealed that more than 85% of employers conduct voluntary self-audits of safety and health conditions; a 60% increase from a similar survey performed in 1981. The survey found that self-audits are performed for a number of reasons, with three of them being the most common.

  1. Careful inspections can reduce injury and illness rates within the workplace by identifying present hazards.
  2. Staying on top of potential hazards is considered the right thing to do by many employers.
  3. Performing self-audits and acting upon any findings helps sustain compliance with OSHA regulations.

Routine self-audits are a cost-effective method of ensuring compliance with OSHA regulations. Performing self-audits can quickly identify safety hazards that need to be corrected prior to formal inspections. Costs associated with occupational safety and health hazards, beyond potential fines, can be reduced if hazards are corrected. Man-hours lost through workers compensation and sick leave can be reduced and productivity can remain high. Some insurance carriers in partnership with OSHA even offer reduced premiums to employers who perform self-audits.

The most thorough means for performing a self-audit is to use a regulatory OSHA checklist for each work area and OSHA-required record keeping. The size and diversity of the business dictates how many checklists are required and how much information should be in each OSHA checklist. While there is not a standard format for an OSHA checklist, several key features should be included:

  • Name of auditor and date inspected
  • Description and CFR cite for all pertinent regulations with a space to note deficiencies
  • A feasible completion date for material deficiencies
  • Initials and/or date when all corrections have been completed

The following list highlights major general industry regulations within work areas and record keeping but should not be considered all-inclusive.

Work Areas

All work areas should be identified. Within these locations, consider the applicability of each subpart of the OSHA standards from CFR Title 29. For:

Record Keeping

In addition to a work area OSHA checklist, written records are often required by OSHA. The following standards cite a required written plan or program in place where applicable:

Emergency Action Plan 1910.38
Process Safety Management of Highly Hazardous Chemicals 1910.119
HAZWOPER Record Keeping 1910.120
Respirator Program 1910.134
Permit-Required Confined Space Program 1910.146
Lockout/Tagout 1910.147
Employee Alarm System 1910.165
Forklift Inspection Log and Training Distribution 1910.178
Electric Power Generation, Transmission and Distribution 1910.269
Electrical Safety-Related Work Practices 1910.333
Bloodborne Pathogens: Exposure Control Plan 1910.1030
Hazard Communication Program 1910.1200
Lab Standard: Chemical Hygiene Plan 1910.1450
Subpart Z–Specific Chemical Substances 1910.1000 to 1910.1450 Appendix B
Posting and Citations Job Safety and Health Poster Form 3165
Accidents, Injuries and Deaths 300 Log
Creating and Maintaining OSHA Checklists for General Industry

The following is an example of what a portion of a workplace OSHA checklist could look like for a flammable storage area. Appropriate components depend on individual situations.


INSPECTION REPORT FOR FLAMMABLE STORAGE AREA

Location:
Inspected By:
Date of Inspection:

(Circle all numbers with deficiencies)

Containers
  1. Are approved containers and portable tanks used for the handling and storage of flammable and combustible liquids? 29 CFR 1910.106(d)(2)
  2. Are all connections on drums and combustible flammable liquid piping vapor and liquid tight? 29 CFR 1910.106(c)(3) (c)(3)
  3. Are all flammable liquids kept in closed containers when not in use? 29 CFR 1910.106(e)(2)(iv)(a)
  4. Are bulk drums of flammable liquids grounded and bonded to containers during dispensing? 29 CFR 1910.106(e)(6)(ii)
  5. Are safety cans used for dispensing flammable or combustible liquids? 29 CFR 1910.106(d)(5)(iii)
  6. Are storage tanks adequately vented to prevent the development of excessive vacuum or pressure as a result of filling, emptying or atmosphere temperature changes? 29 CFR 1910.106(b)(4)(ii)
  7. Are portable tanks equipped with emergency venting to relieve internal pressure from exposure to fire? 29 CFR 1910.106(d)(2)(ii)
  8. Are storage cabinets that store flammable liquids labeled "Flammable, Keep Fire Away"? 29 CFR 1910.106(d)(3)(ii)
  9. Are flammable liquids stored in approved safety cans? 29 CFR 1910.106(d)(2); 29 CFR 1910.144(a)(1)
  10. Are no smoking rules enforced in areas for storage and use of hazardous materials? 29 CFR 1910.106(e)(9)
Fire Extinguishers
  1. Are appropriate fire extinguishers mounted, located and identified so that they are readily accessible to employees? 29 CFR 1910.157(c)(1)
  2. Are all fire extinguishers inspected and recharged regularly, and marked on inspection tags? 29 CFR 1910.157(e)
  3. Is there an adequate number of portable fire extinguishers and of the proper type? 29 CFR 1910.157(d)
  4. For a fixed extinguishing system, is a sign posted warning of the hazards presented by the extinguishing medium? 29 CFR 1910.160(b)(5)
Exits
  1. Are exits properly marked? 29 CFR 1910.37(q)
  2. Do exit signs have an illumination of at least 5 foot-candles? 29 CFR 1910.37(q)(6)
  3. Are exits maintained free of obstructions? 29 CFR 1910.36(d)(1)

Correction completion date:
Corrections have been completed (initials and date):
Supervisor:
Date:


Creating and maintaining and OSHA checklist for general industry operations is by no means the final step. When beginning a safety audit program, several ideas should be kept in mind. A team approach to safety is most effective; rotating people on and off the team will keep ideas fresh and enhance perspective. Inspect thoroughly and frequently; any area, regardless of size, can pose hazards that can crop up seemingly overnight. Once hazards are identified, have a system in place for correction.

Commonly Asked Questions
Q.   Would using checklists reduce fines levied from a formal OSHA inspection?
A.   Recently, OSHA sought public comments on a policy whereby an employers self-audit may be considered evidence of good faith.


Sources

29 CFR 1910

Compliance Audits: Essential Checklists for OSHA, EPA & Other Key Agencies, 1996, J. J. Keller and Associates, Inc. Neenah, WI

(Rev. 1/2012)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Grainger has the products, services and resources to help keep employees safe and healthy while operating safer facilities. You’ll also find a network of safety resources that help you stay in compliance and protect employees from hazardous situations. Count on Grainger for lockout tagout, fall protection equipment, confined space products, safety signs, personal protective equipment (PPE), emergency response and so much more!

Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.


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