According to Bujeaud, OSHA has been shifting its approach to include increased enforcement. The agency plans to add 100 more regulators this year, and it hopes to take in four times as much revenue from citations. "The penalties are big, and they are out there," he said.
"You need to watch your back, protect your assets, and do the right thing."
While Bujeaud covered a number of regulations and compliance issues, at the end of the presentation, he gave a list of top five things companies should be doing now to ensure compliance.
1. If you have over 1,320 gallons of petroleum, you need to have a Spill Prevention, Control, and Countermeasures Plan (SPCCP) in place. This is an EPA regulation that requires companies to recertify that plan every five years. If elements of the plan change, the company must have a new plan. Companies should also be visually inspecting these petroleum tanks on a monthly basis; this needs to be documented!
2. Hazard Assessment and PPE (Personal Protective Equipment) Selection: This OSHA rule requires companies to document hazard assessment and equipment selection. First, see if you can eliminate any hazards at the facility, Bujeaud said. Then, see if there's any equipment that can get rid of the hazard, such as ventilation. Next, see if any administrative controls can reduce the exposure of the hazard to the employee. Companies need to keep this paperwork current and updated as new hazards are introduced into the work area.
3. Employee training is key because these regulatory agencies will interview your employees about your practices. Bujeaud recommends including all environmental, health and safety training in new employee orientation sessions. Most regulations require training upon initial assignment, such as emergency response, hazard communication, PPE, forklift, respiratory protection, respirator fit-testing and hazardous waste management, to name a few.
4. Centralize and organize all your documents in one location, preferably in the business or human resources office, Bujeaud said. Organize waste streams by type and group by year. Keep all training records behind an updated employee list with hire dates. Break down other folders by category. Clearly identify responsibility for compliance stuff, and empower that employee to do it. Budget time and financial resources for compliance. Any dollar you spend on safety compliance will pay you back three- to six-fold, he said.
5. Lastly, obtain certificates of insurance for all outside contractors. They need to be covered for workers' compensation insurance, so you're not stuck paying if an incident occurs.
If you have any questions about OSHA and EPA regulations and whether you're in compliance, seek out environmental, health and safety counsel in your area.