OSHA Ahead Part 4

One of the things that any entity can do in order to reduce the risk of being cited by OSHA is to develop and implement a written safety plan. In this article we will discuss developing the plan in house, and discuss the resources an entity can use to analyze, write and implement the plan.

This is the fourth of six installments of a series devoted to OSHA Compliance development. Prior articles discussed OSHA’s making the automotive industry in Colorado a primary focus for inspections, how to discover compliance issues, and how to address simple non compliance issues. The remaining articles will discuss how to use existing vendors to enhance your safety plan at little or no cost and how to use your safe environment as a negotiation tool to get the best price. For the other articles, click here.

In developing the plan, you will need to also analyze the occupational hazards specific to your industry. The top ten categories of citations in the automotive repair and paint industries involve:

  • Respiratory Protection
  • Insufficient Documentation of Hazards
  • Abrasive Wheel Machinery
  • Wiring Methods, components and equipment for general use
  • General Requirements (meaning that the equipment should not have obvious hazards)
  • Portable fire extinguishers
  • Maintenance, safeguards, and operational features for exit routes.
  • OSHA General Duty Paragraph (Each Employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees [https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=3359&p_table=oshact; viewed May 3, 2016])
  • Flammable and combustible liquids.
  • Metyline Chloride

Of course, this should not be construed as a complete list of the occupational safety issues faced when developing a plan. Some of the issues can be easily identified, such as an emergency exit that is unmarked and / or blocked or not having Safety Data Sheets at hand to explain how to deal with hazardous materials in your workplace. Others may be more difficult to identify. An example would be a practice that violates the OSHA General Duty Paragraph, which can be interpreted very broadly.

Assistance is available from OSHA to assist employers in complying with their regulations. In addition an employer can request a consultation at no charge to assist them in identifying and mitigating safety issues. In the states we operate in, you can contact the following for one.

State Contact
Arizona Arizona Department of Occupational Safety and Health
Colorado Colorado State University
Nebraska Nebraska Department of Labor
New Mexico New Mexico Environment Department
Texas Texas Department of Insurance
Wyoming Wyoming Department of Workforce Services

The next step is to develop the plan. Samples of plan language can be found on the OSHA website by clicking here to help you develop a written safety plan. Once the plan is developed, the plan can be implemented through the organization by advising employees of the plan’s existence and training employees in OSHA compliance.

The final step after implementation is monitoring the safety environment once the plan is implemented, and making modifications to the plan as new safety issues arise.

Although it can be done independently, you can also enlist expertise to develop an effective safety plan that will enable you to be OSHA compliant. Download a copy of our OSHA Compliance Mini-Test to get started.

The AutoRisk team does more than provide brokerage services for the garage industry. We also can provide you with consulting services related to OSHA compliance so that you can avoid the cost and complications of dealing with OSHA compliance issues, as well as prevent losses from happening in the first place which could adversely affect your insurance premium.


Michael Graham

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