OSHA conducted 32,408 site inspections in 2017. More than 18,000 of these occurred as the result of an incident. Environmental incidents also attract the attention of authorities. The EPA collected $2.98 billion in criminal fines, restitution and mitigation in the same period. Other government agencies, such as the U.S. Department of Transportation, are also involved in audit and compliance.
Keeping up with current regulations is a challenge. Changes in legislation aren’t always understood or communicated down the chains of command. But if a government inspector comes calling and finds major violations, no excuse will suffice. Wise companies will conduct an internal compliance assessment of their facilities and operations to make sure they’re managing their risks and meeting federal requirements. Including these as part of their best practices initiatives helps prevent potential citations or safety incidents.
Follow these tips for conducting an internal compliance assessment:
- Set up a cross-functional audit team. Audit teams made up only of engineers or operations workers tend to view compliance issues through a similar lens. Accountants, office workers, nurses or marketers generate some different observations. Diversity can help identify more risks.
- Identify the standards you are measuring your compliance against. Many organizations develop checklists based on the regulations. They use these checklists to test whether they meet the compliance criteria. Making general safety and environmental observations is helpful. But, unless you measure yourself against the standard, you may still fail to comply.
- Develop an assessment plan. Use information about the site, chemicals and activities to define the scope of the internal assessment. The plan should include these basic elements:
- Identify the site functional areas (e.g., production, maintenance, storage, etc.)
- Define key risks in each area (e.g., dispensing, spill containment, fire suppression, etc.)
- Identify the chemicals in use at the facility and obtain relevant SDS information
- Define chemical risks (e.g., hazardous characteristics, storage requirements, compatibility issues, etc.)
- Train your audit teams. It is important that they understand the regulations and checklists you have developed. This will ensure they conduct the audit thoroughly and measure your performance accurately.
- Include systems and procedures in your audit. Companies develop processes and systems that may become outdated over time. Sometimes they forget to evaluate them as codes change. The second most cited OSHA violation in 2017 concerned its Hazard Communication Standard (HCS), a standard that dates to the 1980’s to ensure employees understand the chemical hazards in the workplace. Up-to-date documentation, systems, training efforts and procedures are critical to compliance.
- Publish your audit report with corrective actions. An audit is incomplete unless it results in concrete actions to improve the performance. Action plans with accountable parties and due dates demonstrates a commitment to compliance. Communicate the plan of action across all departments, encouraging feedback and suggestions. Analyze the effectiveness of all corrective actions and discuss the results among workers, adjusting as required.
Keep in mind, maintaining a compliant, safe facility is an ongoing process. Internal audits should be conducted at least once a year to cultivate a sustainable safety culture.
Try the Free STUD-E On-Site Safety Survey
At Justrite, we know that safety is more than a piece of equipment. Staying in compliance takes discipline when regulations and insurance requirements constantly change. We offer a free consultative survey called STUD-E (STORAGE, TRANSFER, USE, DISPOSAL, and EVALUATION). Available in digital format, this tool evaluates the management of volatile hazardous liquids. Our safety experts use the results to recommend the best products and processes to keep your company safe and compliant.
Contact Justrite for Help with Your Compliance Assessment Today
As a leading provider of essential safety solutions for more than a century, Justrite takes a systematic approach to workplace safety. Our technical experts then work with you to create an ecosystem of safety, so your team can work with confidence. Learn more or sign up for our free STUD-E survey today.
- Knowledge at Work. Five Steps to EHS Reporting Compliance
- Globe St. Why it Pays to Add an Environmental Compliance Audit
- EPA. EPA Announces 2017 Annual Environmental Enforcement Results
- Global Safety Management. By the Numbers: 2017 OSHA Compliance Statistics You Should Know
- Safety+Health. OSHA’s Top 10 Most Cited Violations for Fiscal Year 2017
- United States Department of Labor. OSHA Enforcement