Industry

Public Sector

Will Your Campus Be Ready Should OSHA Come Calling?

3/21/19
Sally J. Smart, Technical Safety Specialist, W.W. Grainger, Inc.

Generally all worksites are subject to Occupational Safety and Health Administration (OSHA) inspections. Most private universities in the U.S. with 50 or more employees fall under Federal OSHA jurisdiction. Campuses are not immune from OSHA requirements and need to be compliant with all governing standards.

Getting your campus ready for OSHA means knowing what standards apply, learning from other facilities' inspections and applying those lessons to your campus.

Where OSHA Applies to Campuses

While not all safety and health standards apply to every facility, many are common to all. These requirements extend to work done by contractors and other third parties. OSHA focuses on six key areas when assessing any campus: imminent dangers, severe injuries and illnesses, worker complaints, referrals from employees, targeted inspections and follow-up inspections.

In 2016-2017 alone, federal OSHA issued over $100,000 in fines across 26 citations to campuses, a trend that continued through 2018. These citations come with mandatory remediation, steep fines for non-compliance and potential legal consequences if ignored. Keeping your campus compliant is the best means for avoiding a public and potentially costly citation.

Major Violations on Campus

Campuses tend to have a variety of equipment and buildings with different ages.  This can lead to a wide range of potential violations and you must be prepared to account for them. From 2016 to 2018, campuses received a range of citations for common issues. Citations were issued for improper safety controls on machinery and equipment; cluttered or mislabeled exit routes; improper use of mobile work platforms; inadequate protections for openings on walls and floors; and missing signage or protections for confined spaces.   These types of citations are especially concerning, because they can happen on any campus at any time with limited negligence.

One special class of violation can also be common on older campuses: asbestos. Campuses are required to take precautions to secure or remove known sources of asbestos, and prevent damage that can lead to student and faculty health risks. Improper maintenance or neglect can mean steep fines and required mitigation work.

Lessons to Be Learned

Previous OSHA citations and fines offer several lessons about preventing violations.

Lesson 1 - Procure for Safety: The choices you make in procurement have a direct impact on your campus’ ability to follow and exceed OSHA regulations. Choosing the right signage, protective gear and equipment, and even machinery can make the difference between a clean review and multiple citations and fines.

To stay ahead of regulations, ensure that your orders contain the right preventative equipment for any known risks, including confined spaces, worksites, and cracks or holes. These tools keep workers and students safe, and are a small investment compared to fines. Machinery should be issued from the manufacturer with specific safety instructions that should be followed with each use to prevent injury and citation. Any repairs to equipment should be completed by the original manufacturer or in accordance with their recommendations.

Lesson 2 - Select the Right Contractors: Your campus is ultimately responsible for the actions of any contractors or workers you hire to repair and improve your facilities. Only work with third parties that meet or exceed your vetting standards.

Contractors should always operate in line with the OSHA standards that apply to your campus. Worksites must be clearly marked, well protected, and encourage safe operations at all times. Any machinery used must meet safe operating requirements and be operated in accordance with manufacturer recommendations.

Lesson 3 - Constantly Review and Educate: OSHA standards can change in small or large ways quite often, and there's no excuse for not knowing the latest standards. It is crucial for your team to constantly review your facility for compliance and to have access to the latest information and training. Trained teams should inspect the campus as part of their daily rounds or regular maintenance schedule. Focusing on known risks or recent changes can reduce the workload of staying compliant. Inspecting a recent construction project for violations, for example, can save time and help concentrate focus on other potential  high-risk areas.

Continual education helps your team quickly react to changes in OSHA regulations, learn from citations and fines at other campuses and properly assess current compliance with any new provisions. Regular training sessions or onsite reviews can be an effective tool in raising safety and health awareness throughout your team.

Prior to joining Grainger, Sally was the Director of Quality, Regulations and Safety for two chemical manufacturers and compressed gas packagers. Sally is a Board Certified Safety Professional® (CSP), Certified Environmental Safety and Health Trainer®, and Safety Trained Supervisor®; and a Qualified Safety Sales Professional (QSSP). Sally is OSHA – 30 hour trained for both Construction and General Industry and is an OSHA Authorized Outreach Trainer for General Industry. She is also MSHA Part 46 and Part 48 New Miner 5000-23 and HACCP certified.

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