Facility Audit Checklist

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## e. OSHA ENFORCEMENT FOR NON-AGRICULTURE WORKSITES - 1. For non-agriculture worksites other Part 1910 standards may be cited for hazards which are not covered under 1910.142. For non-agriculture worksites, the TLC standard has no provisions that specifically apply to fire protection, so those standards are not explicitly pre-empted by the TLC standard. The same is true for 1910.36 and 37 (exit routes). However, 1910.38 (emergency action plans) applies only where an emergency action plan is required by a particular OSHA standard, so it cannot be used with TLCs. - 2. Examples of temporary labor camp housing for non-agriculture worksites would be for the construction industry, oil and gas industry, and garment industry in the Pacific territories. Such housing for these industries may also be found in large cities and rural areas in various parts of the United States. - 3. The choice of standards issue, discussed in Paragraph d.1., Choice of Standards on Construction Prior to April 3, 1980, does not apply to non-agriculture temporary housing. - f. EMPLOYEE OCCUPIED HOUSING Generally, conduct occupied housing facility inspections as soon as feasible so that any hazards identified may be corrected early in the work season. - 1. Since employees may not speak English, or may only speak English as a second language, every effort shall be made to send a bilingual CSHO on the inspection or have a bi-lingual person accompany the CSHO to translate conversations with employees. - 2. CSHOs shall conduct inspections in a way that minimizes disruptions to those living in the housing facilities. If an occupant of a dwelling unit refuses entry for inspection purposes, CSHOs shall not insist on entry and shall continue the rest of the inspection unless the lack of access to the dwelling unit involved would substantially reduce the effectiveness of the inspection. In that case, valid consent should be obtained from the owner of the unit. If the owner also refuses entry, the procedure…

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## 29 CFR 1910 (OSHA) - (i) What-If; - (ii) Checklist; - (iii) What-If/Checklist; - (iv) Hazard and Operability Study (HAZOP): - (v) Failure Mode and Effects Analysis (FMEA); - (vi) Fault Tree Analysis; or - (vii) An appropriate equivalent methodology. - (3) The process hazard analysis shall address: - (i) The hazards of the process; - (ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; - (iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); - (iv) Consequences of failure of engineering and administrative controls; - (v) Facility siting; - (vi) Human factors; and - (vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. - (4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. - (5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

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Oregon Occupational Safety and Health Division Oregon Administrative Rules AO 3-[redacted street address] for medium to large facilities to enhance coordination and communication during emergencies for on plant operations and with local community organizations is for employers to establish and equip an emergency control center. The emergency control center would be sited in a safe zone area so that it could be occupied throughout the duration of an emergency. The center would serve as the major communication link between the on-scene incident commander and plant or corporate management as well as with the local community officials. The communication equipment in the emergency control center should include a network to receive and transmit information by telephone, radio or other means. It is important to have a backup communication network in case of power failure or one communication means fails. The center should also be equipped with the plant layout and community maps, utility drawings including fire water, emergency lighting, appropriate reference materials such as a government agency notification list, company personnel phone list, SARA Title III reports and safety data sheets, emergency plans and procedures manual, a listing with the location of emergency response equipment, mutual aid information, and access to meteorological or weather condition data and any dispersion modeling data. - 14. Compliance Audits. Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. A small process or plant may need only one knowledgeable person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer's systems are effectively implemented. The audit should be conducted or lead by a person knowledgeable in audit techni…

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Division 2 AO 3-2019 Oregon Administrative Rules The selection of effective audit team members is critical to the success of the program. Team members should be chosen for their experience, knowledge, and training and should be familiar with the processes and with auditing techniques, practices and procedures. The size of the team will vary depending on the size and complexity of the process under consideration. For a large, complex, highly instrumented plant, it may be desirable to have team members with expertise in process engineering and design, process chemistry, instrumentation and computer controls, electrical hazards and classifications, safety and health disciplines, maintenance, emergency preparedness, warehousing or shipping, and process safety auditing. The team may use part-time members to provide for the depth of expertise required as well as for what is actually done or followed, compared to what is written. An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Utilizing the audit procedure and checklist developed in the preplanning stage, the audit team can systematically analyze compliance with the provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of the training program as part of the overall audit. The team will review the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the standard's requirements, documentation, etc. Through interviews, the team can determine the employee's knowledge and awareness of the safety procedures, duties, rules, emergency response assignments, etc. During the inspection, the team can observe actual practices such as safety and health policies, procedures, and work authorization pr…

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- 2. During the walkaround, the CSHO shall inform the employer of the violations noted and what information will be required for reviewed upon completion of the walk. This information will be reviewed on-site, and an employer request letter is discouraged unless the information can only be obtained from an outside source such as corporate headquarters. ## b. INJURY AND ILLNESS RECORDS - 1. Collection of Data - A. The establishment's injury and illness records for the last three calendar years will be reviewed as follows: - · Comprehensive inspections; - · Accident, fatality, and catastrophe investigations; - · Any complaint/referral inspection where recordkeeping or injury allegations arise; - · When otherwise deemed necessary by the CSHO. The CSHO shall document the justification for the review. - B. Upon review of an employer's injury and illness records, enter the data into OIS. This shall be done for all general industry, construction, maritime, and agriculture inspections and investigations. - C. For exemptions, see 1904.1 - Partial exemption for employers with 10 or fewer employees, 1904.2 - Partial exemption for establishments in certain industries, and 1904 Subpart B App A - Partially Exempt Industries for exemptions. ## 2. Information to be Obtained - A. CSHOs shall request copies of the OSHA 300 Logs, the total hours worked and the average number of employees for each year, and a roster of current employees. - B. If CSHOs have questions regarding a specific case on the log, they shall request the OSHA 301s or equivalent form for that case. - C. CSHOs shall check if the establishment has an on-site medical facility and/or the location of the nearest emergency room where employees may be treated. - NOTE: The total hours worked and the average number of employees for each year can be found on the OSHA 300A for all past years. - 3. Construction - For construction inspections/investigations, the OSHA 300 information for the prime/general contractor and sub-…

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Division 3 AO 1-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - (xvii) Warning labels and decals originally supplied with the equipment by the manufacturer or otherwise required under this standard: missing or unreadable. - (xviii) Originally equipped operator seat (or equivalent): missing. - (xix) Operator seat: unserviceable. - (xx) Originally equipped steps, ladders, handrails, guards: missing. - (xxi) Steps, ladders, handrails, guards: in unusable/unsafe condition. - (3) This inspection must include functional testing to determine that the equipment as configured in the inspection is functioning properly. - (4) If any deficiency is identified, an immediate determination must be made by the qualified person as to whether the deficiency constitutes a safety hazard or, though not yet a safety hazard, needs to be monitored in the monthly inspections. - (5) If the qualified person determines that a deficiency is a safety hazard, the equipment must be taken out of service until it has been corrected, except when temporary alternative measures are implemented as specified in 1926.1416(d) or 1926.1435(e). See 1926.1417. - (6) If the qualified person determines that, though not presently a safety hazard, the deficiency needs to be monitored, the employer must ensure that the deficiency is checked in the monthly inspections. - (7) Documentation of annual/comprehensive inspection. The following information must be documented, maintained, and retained for a minimum of 12 months, by the employer that conducts the inspection: - (i) The items checked and the results of the inspection. - (ii) The name and signature of the person who conducted the inspection and the date. - (g) Severe service. Where the severity of use/conditions is such that there is a reasonable probability of damage or excessive wear (such as loading that may have exceeded rated capacity, shock loading that may have exceeded rated capacity, prolonged exposure to a corrosi…

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## 29 CFR 1910 (OSHA) the facility or area being audited. The essential elements of an audit program include planning, staffing, conduting the audit, evaluation and corrective action, follow-up and documentation. Planning in advance is essential to the success of the auditing process. Each employer needs to establish the format, staffing, scheduling and verification methods prior to conducting the audit. The format should be designed to provide the lead auditor with a procedure or checklist which details the requirements of each section of the standard. The names of the audit team members should be listed as part of the format as well. The checklist, if properly designed, could serve as the verification sheet which provides the auditor with the necessary information to expedite the review and assure that no requirements of the standard are omitted. This verification sheet format could also identify those elements that will require evaluation or a response to correct deficiencies. This sheet could also be used for developing the follow-up and documentation requirements. The selection of effective audit team members is critical to the success of the program. Team members should be chosen for their experience, knowledge, and training and should be familiar with the processes and with auditing techniques, practices and procedures. The size of the team will vary depending on the size and complexity of the process under consideration. For a large, complex, highly instrumented plant, it may be desirable to have team members with expertise in process engineering and design, process chemistry, instrumentation and computer controls, electrical hazards and classifications, safety and health disciplines, maintenance, emergency preparedness, warehousing or shipping, and process safety auditing. The team may use part-time members to provide for the depth of expertise required as well as for what is actually done or followed, compared to what is written. An effective audit inc…

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experienced by employees, duration and frequency of exposures to the hazard, employee interviews, sources of potential health hazards, types of engineering or administrative controls implemented by the employer, and PPE being provided by the employer and used by employees. ## B. Employer's Occupational Safety and Health System CSHOs shall request and evaluate information on the following aspects of the employer's occupational safety and health system as it relates to the scope of the inspection: ## 1. Monitoring The employer's system for monitoring safety and health hazards in the establishment should include a program for self-inspection. CSHOs shall discuss the employer's maintenance schedules and inspection records. Additional information shall be obtained concerning activities such as sampling and calibration procedures, ventilation measurements, preventive maintenance procedures for engineering controls, and laboratory services. Compliance with the monitoring requirements of any applicable substance-specific health standards shall be determined. ## 2. Medical CSHOs shall determine whether the employer provides the employees with preplacement and periodic medical examinations. The medical examination protocol shall be requested to determine the extent of the medical examinations and, if applicable, compliance with the medical surveillance requirements of any applicable substancespecific health standards. ## 3. Records Program CSHOs shall determine the extent of the employer's records program, such as whether records pertaining to employee exposure and medical records are being maintained in accordance with 29 CFR 1910.1020 and UAC R614-1-10 or where a vertical standard has provisions for employee access to the records. ## 4. Engineering Controls CSHOs shall identify any engineering controls present, including substitution, isolation, general dilution and local exhaust ventilation, and equipment modification. ## 5. Work Practice and Administrative …

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\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ - (vi) You must set up a good communication system between the hoist operator and the appointed individual in charge of the derrick operations before any work on the equipment is started. - (vii) Welding repairs must be approved by an appointed person. - (b) After adjustments and repairs have been made you must not operate the derrick until all guards have been reinstalled, safety devices reactivated, and maintenance equipment removed. ## (3) Adjustments and repairs . - (a) You must correct any unsafe conditions disclosed by inspection before operation of the derrick is resumed. - (b) You must maintain adjustments to ensure correct functioning of components. - (c) You must provide repairs or replacements promptly as needed for safe operation. The following are examples of conditions requiring prompt repair or replacement: - (i) Hooks showing defects described in WAC 296-24-[redacted postal code] (2)(f) must be discarded. - (ii) All critical parts which are cracked, broken, bent, or excessively worn. - (iii) Pitted or burned electrical contacts should be corrected only by replacement and in sets. Controller parts should be lubricated as recommended by the manufacturer. - (iv) All replacement and repaired parts must have at least the original safety factor. [Statutory Authority: RCW 49.17.010, .040, .050, and .060. 15-24-100 (Order 15-04), § 296-24-[redacted postal code], filed 12/01/2015, effective 01/05/2016. Order 73-5, § 296-24-[redacted postal code], filed 5/9/73 and Order 73-4, § 296-24-[redacted postal code], filed 5/7/73.] ## WAC 296-24-[redacted postal code] Rope inspection. - (1) Running ropes . You must make a thorough inspection of all ropes in use at least once a month and a full written, dated, and signed report of rope condition kept…

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- e. During inspections, CSHOs shall encourage employers to correct hazards as quickly as possible. Particular attention shall be paid to identifying instances of failure to correct and violations repeated from season to season. These violations shall be recommended for citation in accordance with normal procedures. - f. Primary Concern. In conducting a TLC inspection, the CSHO shall be primarily concerned with those facilities or conditions which most directly relate to employee safety and health. Accordingly, all housing inspections shall address at least the following: - i. Site. The location of the site in relation to swamps, pools, sinkholes and other surfaces where water may collect and remain for extended periods. The site shall be in a clean and sanitary condition; i.e., free from rubbish, debris, waste paper, garbage and other refuse. - ii. Shelter. Whether the shelter provides protection against the elements and whether the rooms are used for combined purposes of sleeping, cooking and eating. For rooms used for sleeping purposes, determine the number of occupants and size of the rooms. Determine for all rooms whether there is proper ventilation and screening. - iii. Water Supply. Whether the water supply has been approved by the appropriate local health authority; determine the location of hydrants. - iv. Toilet Facilities. The type, number, location and sanitary conditions of toilet facilities. - v. Laundry, Handwashing and Bathing Facilities. The number, locations and conditions of these facilities. - vi. Solid Wastes. Determine the type, number, locations and conditions of solid waste containers, and whether there are any infestations of insects or rodents. - vii. First Aid Facilities. First aid facilities shall be readily available. - g. Dimensions. The relevant dimensions and ratios specified in 29 CFR 1910.142 or UAC R614-3 are mandatory; however, it is inappropriate to recommend a citation for minor variations from specific dimensions…

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## 29 CFR 1910 (OSHA) If the employer wants specific employees in the release area to control or stop the minor emergency or incidental release, these actions must be planned for in advance and procedures developed and implemented. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work before they respond to handle an actual release. The employer's training program, including the Hazard Communication standard training is to address the training needs for employees who are expected to handle incidental or minor releases. Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly hazardous chemical occurs, the employer through preplanning will have determined in advance what actions employees are to take. The evacuation of the immediate release area and other areas as necessary would be accomplished under the emergency action plan. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or use employees to render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by §1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. If outside assistance is necessary, such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by HAZWOPER. The safety and health protections required for emergency responders are the responsibility of their employers and of the onscene incident commander. Responders may be working under very hazardous conditions and therefore the objective is to have them competently led by an on-scene incident commander and the comm…