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Critical 10 Minute Drill Before Letting CAL-OSHA in Your Plant
By John Holland, President, Assured Compliance Solutions

Your first 10 minutes, before you allow a CAL-OSHA enforcement officer to inspect your facility, are critical! You should be friendly and cooperative with CAL-OSHA, and rarely should you ever deny them access.

Once you have determined why CAL/OSHA enforcement is visiting your facility, if you are working with a Safety Rep., you can tell CAL/OSHA something like the following to the enforcement officer…"We are proud of our safety program that an outside consulting firm has helped us develop and since our consultant is heavily involved in our compliance, he wants to talk to you before you inspect our facility. If he does not respond within 10-15 minutes, we'll go ahead today and fully cooperate."

Offer the officer a cool drink while they wait. And, offer to get them any safety documentation they'd like to see while they're waiting for my return call. They may ask to see your last five years of your injury reporting OSHA Form 300 and 300As, your SDS book, and required safety programs such as SB 198 Injury and Illness Prevention, Hazard Communication, Control of Hazardous Energy (Lockout Tagout Blockout), Motorized Forklift, etc.

While you are waiting for us to return your call, if possible, excuse yourself from the conference room and have a supervisor or trusted lead employee do a quick plant tour and make sure the following is correct in your plant: These key items often result in citations.

  1. All guards and side panels are properly installed and closed on all machines.
  2. All secondary chemical containers are legibly labeled with your ACS supplied warning labels.
  3. All lids are closed on all chemical products and waste drums.
  4. Rag containers are closed.
  5. You have unblocked access to all eyewash stations, electrical panels, and fire extinguishers.
  6. Your plant Safety Data Sheet Book is readily available.
  7. Any other obvious safety issues are quickly rectified.

If you are not currently partnering with a competent safety consulting company, you can still prep your plant before allowing CAL/OSHA Enforcement onto your plant floor. You, as the company owner or plant manager, can alert your key person in charge of safety to conduct the above seven point quick plant tour and clean-up while you are personally meeting with the enforcement officer. You could even say to the enforcement officer, "My production manager, who is in charge of plant safety, is currently involved in the plant for about 15 more minutes. How can I help you while we wait for him/her to join us?

You can tell your trusted supervisor who is doing the quick tour and "clean-up" that they have a maximum of 10 minutes for this "quickie plant makeover", and then he/she is to join you in the conference room with the CAL/OSHA officer to participate in the plant audit with you. Please practice this 10 minute plant inspection now, before any CAL-OSHA officer is actually in your plant conference room!

Do fully cooperate with the CAL/OSHA officer, when possible fix any issues on-the-spot, take good notes and clarify any problem areas the officer identifies. And, please call John Holland or your current consultant as soon as the officer leaves. We should immediately start strategizing your potential response to any possible citations.

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