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INTER-AMERICAN CONFERENCE OF MINISTERS OF LABOR (IACML). May 19, 2009. Sanji Kanth, PE Occupational Safety & Health Administration General Industry Enforcement Directorate of Enforcement Programs. OSHA Regional Offices. OSHA’s Directorate of Enforcement Programs.
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INTER-AMERICAN CONFERENCEOF MINISTERSOF LABOR (IACML) May 19, 2009 Sanji Kanth, PE Occupational Safety & Health Administration General Industry Enforcement Directorate of Enforcement Programs
OSHA’s Directorate of Enforcement Programs • Office of General Industry Enforcement • Office of Health Enforcement • Office Maritime Enforcement • Office of Whistle Blower Protection
Enforcement Programs/Initiatives • Designed to aid OSHA reduce workplace fatalities, injuries, and illnesses by targeting the most hazardous workplaces and the employers with the highest injury and illness rates. • Strategic mechanisms include Site Specific Targeting (SST), the Enhanced Enforcement Program (EEP), National Emphasis Programs (NEPs), and Local Emphasis Programs (LEPs).
Categories of Inspections • Programmed and Unprogrammed • Programmed • Site Specific Targeting • Enhanced Enforcement Program • National Emphasis Programs (NEPs) • Local Emphasis Programs (LEPs)
Categories of Inspections • Unprogrammed • Fatalities/catastrophes • Complaints • Referrals • Monitoring • Follow up
OSHA Inspection Scheduling Priortity • Imminent Danger • Fatalities/Catastrophes • Complaints/Referrals • Employees • Other Interested Parties • Programmed Inspections
Site-Specific Targeting (SST) • SST is for 40 or more employees • OSHA Data Initiative (ODI) Survey • ODI collects data from 80,000 employers • The first SST program was initiated in April 1999 • The SST consists of three inspection lists, a primary, secondary and tertiary list
Enhanced Enforcement Program (EEP)— • If an inspection is classified as an EEP case it may receive additional enforcement efforts: • An enhanced follow-up inspection; • More stringent settlement provisions; and • Other workplaces of the employer may be inspected.
National Emphasis Programs • Developed by the Directorate of Enforcement Programs • Developed by the Directorate of Construction • Developed by the Directorate of Evaluation and Analysis • Recordkeeping
National Emphasis Programs • Lead • Crystalline Silica • Amputations • Combustible dust • Oil refineries • Shipbreaking operations • Trenching
National Emphasis Programs • NEPs Under development • Chemical Plants – process safety management • Primary metals • Occupational asthma • Flavorings and Diacetyl • Oil and gas well drilling • Recordkeeping
Local Emphasis Programs • Developed by an Area Office or Region • Regional and Regional Solicitors approval • 140+ LEPs • Examples: • Lead • Silica • residential construction • metals
Where is Enforcement Going • Impacting whole corporations and industries • Corporate settlement agreements • Enhanced enforcement program • Letters to industry • Letters to corporations • Other methods
OSHA Compliance Assistance Resources • Safety and Health Topics Pages • Fact Sheets • Posters • Safety and Health Information Bulletins OSHA’s Combustible Dust Poster