Occupational Safety and Health Administration (OSHA) Compliance Audit Using the Plan-Do-Check-Act (PDCA) model we discussed in Units I, II, and III, here you will address the “check” (C) and “act” (A) portion in this assignment. Continuing with the scenario presented in the Unit VII Assignment (refer to Unit VII Assignment in the syllabus), you are now assuming the role of an OSHA compliance safety and health officer who has been assigned to perform an audit of the facility where the accident occurred. You have been asked to evaluate the company’s safety management system (SMS) to determine if there were any deficiencies in the system that could have caused the accident. You are required to prepare a summary of your audit process to evaluate the post-accident findings compliant with OSHA standards.
Integrated Safety Management Systems
Inspecting a workplace after an accident may seem like a straightforward task. However, as an OSHA safety inspector, I will be looking for the risks or hazards that the SMS at the workplace has omitted. Hopefully, it will be a learning experience for everyone involved, and the workplace will be a safer place after the audit is complete.
Opening and Closing Conferences
Since the audit is an External Third Party audit, the auditor would be involved, the safety manager, and the employees involved such as the maintenance manager in the opening conference. The injured employee and the employees who witnessed the accident or had information about the accident or the forklift could be met with at another time. Other than those relevant employees, I would invite as many employees as wanted to be involved in the audit to join in though. McKinnon (2017) says, “As many employees as possible should be involved in the safety auditing process. This provides further training” (McKinnon, 2017, p. 91). I would also invite a mechanic from a neutral business so that there was a neutral expert on hand to look at the brakes on the forklift, but that would also be at another time before the audit. This way I would have the relevant reports and my own eye witness view of the setting of the accident.
For the closing conference, all those involved/interested would be invited. McKinnon (2017) says, “Once all the documentation has been reviewed and systems are verified, a feedback session is held with all concerned parties. Here, the auditors present feedback on the strengths and weaknesses of the system, and at the conclusion, announce the score for each section and the total for the entire safety system” (McKinnon, 2017, p. 95). The closing conference is where all parties find out the results of the audit, and that is important for everyone to know.
OSHA Standards
The OSHA standards that apply to the accident and should be considered in an OSHA compliance audit include 29 CFR 1910.78 for powered industrial trucks (PITs) also known as forklifts, which says, “All new powered industrial trucks acquired and used by an employer shall meet the design and construction requirements for powered industrial trucks established in the "American National Standard for Powered Industrial Trucks” (OSHA, 2003). The age of the forklift involved in the accident is unknown, but it should still comply with the OSHA standard.
Other OSHA standards related to the forklift come from the standard 1910.178q Maintenance of Industrial Trucks. Portions of that standard read: “1910.178(q)(1) Any power-operated industrial truck not in safe operating condition shall be removed from service. All repairs shall be made by authorized personnel” and 1910.178(q)(7) “Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily” (OSHA, 2019). While it is unclear if the employee injured in the accident inspected the forklift in compliance with the OSHA safety standard, but he did know that the brakes did not feel right.
Finally, another relative OSHA standard is one that applies to lighting, 1926.56 (a), which says, “General Construction areas, ramps, runways, corridors, offices, shops, and storage areas shall be lighted to not less than the minimum illumination intensities . . . while any work is in progress (OSHA, 2019). The illumination intensity in the area where the accident occurred is unclear.
Items to Look for to Determine Compliance
The first thing I would look for is the maintenance log on the forklift. Then I would ask to see if the inspection had been done on the day of the accident. I would want the mechanic to look at the brakes on the forklift and at other parts of it to determine if it was in safe working order. The next item that I would be sure to look at is the lighting in the area where the accident occurred. I would bring an illumination tester to see if the amount of lighting in the area (and in other areas of the facility) complied with OSHA’s standard. While touring the facility, I would also make notes about risks or hazards that I see.
Scoring System
While there are several ways to score items on an audit list. One way is just to say “go” or “no go,” but that is not detailed enough. A piece of equipment could have a problem but still be useable. I want that diminished level of acceptability noted and detailed further. That is why I would use the numbered scoring system that McKinnon (2017) describes. He says, “Some rank fulfillment of the requirements on a 1–10 scale, where (10) indicates complete co