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The Consultation Process |
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What
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Getting Started |
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| How does the process work? Consultation service
begins with your request-by telephone call, correspondence, or contact during
a promotional visit by a consultant. Some services, such as a review of
proposed new production processes from a safety and health point of view,
may be conducted at locations away from the employer's worksite. When you
request on-site services, the consultant will confer with you at the outset
regarding the specific needs or concerns you describe. The consultant may
also research any special problems you mention in the initial contact before
scheduling a visit to your establishment. Although you may include within
the scope of the request all work conditions at the work site and your entire
safety and health program, you do have the option to limit the visit to
one or more specific problems. However, if the consultant observes hazards
that are outside the scope of the request, you must be notified of their
presence.
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Opening Conference |
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Upon arrival at your work site for a scheduled visit, the
consultant will briefly review his/her role during the visit and may, if
requested, review with you your safety and health program. The consultant
will explain the relationship between on-site consultation and OSHA enforcement
activity and further explain your obligation to protect employees in the
event that "serious" hazardous conditions are identified. Also,
the consultant will explain that employee participation is expected during
the consultation process. At unionized sites employee representatives must
be afforded the opportunity to participate in an opening and closing conference
with the consultant, and will have the right to participate in the walk-through
of the workplace. At all other sites the consultant must have reasonable
opportunity to confer with employees. |
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Walking Through the Workplace |
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During the activity, you and the consultant will examine conditions
in your workplace. The consultant will identify any specific hazards and
provide advice and assistance in establishing or improving your safety and
health program and in correcting any identified hazardous conditions. At
your request, assistance may also include education and training for you,
your supervisors, and your employees. |
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| Worker participation in the walk-through is strongly encouraged.
Employees that are well aware and alert to possible hazards can more easily
work with you to identify and correct potential injury and illness hazards.
At a minimum, the consultant must be able to talk freely with workers during
the walk-through to help identify and judge the nature and extent of specific
hazards and, where requested, to evaluate your safety and health program. |
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| The consultant will study either your entire operation or
focus on those specific areas, conditions, or hazards for which you have
requested assistance. He/she will also offer advice and assistance on other
safety or health hazards that might not be covered by current OSHA standards
but that still pose safety or health risks to your employees. |
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In a complete review of a company's operation, the consultant
will look for mechanical and physical hazards by examining the structural
condition of the building, the condition of the floors and stairs, and the
exits and fire protection equipment. During the tour of the workplace, he/she
will review the layout for adequate space in aisles and between machines,
check equipment, such as forklifts, and examine storage conditions. Control
of electrical hazards and machine guards also will be considered. |
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The consultant will check the controls used to limit worker
exposure to environmental hazards, such as toxic substances and corrosives
and especially air contaminants. He/she will check to see if all necessary
technical and personal protective equipment is available and functioning
properly. Also, the consultant will note any problems workers may encounter
from exposure to noise, vibration, extreme temperatures, or unusual lighting
on approaches and offer means and techniques commonly used for the elimination
or control of hazards. |
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Work practices, including the use, care, and maintenance of
hand tools and portable power tools, as well as general housekeeping, are
of interest to the consultant. He/she will want to talk with you and workers
about items such as job training, supervision, safety and health orientation
and procedures, and equipment maintenance and repair. |
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In addition, the consultant will want to know about any ongoing
safety and health programs your firm has developed. If your firm does not
have a program or if you would like to make improvements, the consultant
will, at your request, offer advice and technical assistance on establishing
or improving a program. Management and worker attitude toward safety and
health will be considered in this analysis as well as current injury and
illness data. The consultant will need to know about how you and your employees
communicate about safety and health as well as any in-plant safety and health
inspection programs. |
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Closing Conference |
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Following the walk-through survey, the consultant
will meet with you and the participating employees in a closing conference.
Separate closing conferences with the management and employee representative
may be held. This session offers the consultant an opportunity to discuss
measures that are already effective and any practices that warrant improvement.
During this time, you and the consultant can discuss problems, possible
solutions, and time frames for eliminating or controlling any "serious"
hazards identified during the walk-through. |
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In rare instances, the consultant may find an "imminent
danger" situation during the walk-through. In such situations, an employer
must take immediate action to protect all affected workers. If the consultant
finds a hazard that is considered "serious" under OSHA criteria,
he/she will work with you to develop a mutually acceptable plan and schedule
to eliminate or control that hazard. During this time, you are required
to advise affected employees of the hazards and to notify them when the
hazards are corrected. Union representatives must be provided with a copy
of the hazards found. Consultants offer general approaches and options as
well as technical assistance on the correction of hazards when they have
the expertise. |
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The consultant may also offer suggestions for establishing,
modifying, or adding to the company's safety and health program in order
to make such programs more effective. Such suggestions could include worker
training, changing work practices, methods for holding supervisors and employees
accountable for safety and health, and various methods of promoting safety
and health. |
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Hazard Correction and Program Assistance |
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After the closing conference, the consultant will send you
a written report explaining the findings and confirming any correction period
agreed upon. The report may also include suggested means or approaches for
eliminating or controlling hazards as well as recommendations for making
your safety and health program effective. You will also receive and be required
to post a list of those hazards identified during the consultation visit.
You will be required to make information about corrective methods proposed
by the consultant and other-than-serious hazards identified available to
employees and their representatives. If a union representative participates
in the consultative visit with the consultant, a copy of the list of hazards
must be made available to that representative. The list of hazards may be
posted electronically. |
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You are, of course, free to contact consultants for additional
assistance at any time. |
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Ultimately, you must correct "serious" hazards so
that each consultation visit achieves its objective-effective worker protection.
If an employer fails or refuses to eliminate or control an identified "serious"
hazard (or any "imminent danger") according to the plan and any
extensions granted subsequently, that situation may be referred from Consultation
to the appropriate OSHA enforcement office for review and action. This is
a rare occurrence. |
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