Category archive of ORC HSE Viewpoints

OSHA Inspections and Document Requests

Over the last several years ORC HSE has received enquiries from member companies in regard to excessive document requests at the beginning of an OSHA inspection. In some cases the requests by the Agency for documents and copies of programs will run two or more pages in length. These requests are provided to the employer during the opening conference. The concerns raised by ORC HSE member companies is that the requests seem open-ended, are very long, and contain requests for information that do not appear to be at all related to the reason and scope of the OSHA inspection as explained by the compliance officer. According to these companies the time involved to produce the items asked for would be excessive, especially for a limited scope inspection.

OSHA’s Treatment of Voluntary Employer Health and Safety Self-Audits

In 1996, ORC HSE (formerly ORC) visited the Occupational Safety and Health Administration (OSHA) on behalf of several member companies to request that the agency limit OSHA compliance safety and health officers’ practice of asking to see employer self-audits during the normal course of their inspections.

OSH Network Special Event: Meet Dr. Sidney Dekker

We are very excited to announce that one of the world’s foremost experts on incident causation and human error, Sidney Dekker, will provide unique opportunity to learn and interact with him at our OSH Group meeting on February 6, 2019. Dr. Dekker’s ideas have created a revolution in thinking throughout the safety world…

A Blow to OSHA Enforcement

A recent decision by the U.S. Court of Appeals for the 11th Circuit has dealt a serious blow to OSHA’s long-standing authority in determining the appropriate scope of safety and health inspections.

ORC HSE Book Review: The True Story of Rebuilding Puerto Rico, One Meal at a Time

An Anthony Bourdain Book, published by HarperCollins, 2018. Jose Andres is a DC-based celebrity chef who dedicates much of his time to disaster relief. His new book, We Fed an Island, focuses on his first-hand experience organizing an unprecedented food response campaign after Hurricane Maria hit Puerto Rico last year. The campaign prepared 3 million meals using 20,000 volunteers and involving 24 kitchens. Andres, a native of Spain, never graduated from high school, yet his insights into the failures of traditional disaster response systems and thinking provides valuable lessons for health and safety professionals.

ORC HSE Comments to OSHA on Tracking of Workplace Injuries and Illnesses

ORC HSE Partner Steve Newell and colleagues have submitted comments on OSHA’s Notice of Proposed Rule Making (NPRM) “Improve Tracking of Workplace Injuries and Illnesses” that appeared in the July 30 Federal Register.

High Reliability Organizations (HROs) – Book Review

If you are interested in human and organizational performance (HOP) and or “new view” safety thinking you will especially value the important insights found in Organizing for Reliability: A Guide for Research and Practice, edited by Rangaraj Ramanujam and Karlene Roberts, and published by Stanford University Press, 2018. The book is a compilation of chapters written by more than a dozen diverse experts, many of whom have decades of experience is the study of reliability. One aim of the book is to identify areas for future research.

Cardinal Rules, Employee/Management Collaboration, and Improving Safety Performance

Cardinal Rules have been around for a long time and can go by a variety of names, such as Golden Safety Rules, fundamental rules, critical rules, etc. Simply put, they are usually a set of rules about the behavior of frontline employees that the employer has identified as important to good safety performance and accident prevention in their operations. Some can be common across companies like “always de-energize equipment before working on it”, while others may be very specific to a particular company and its operations. Historically, they have often been implemented with some form of “zero tolerance” policy that says something like “if you violate these rules you will be disciplined, up to and including termination”.

PPE Hazard Assessments – Are you meeting all of the requirements?

An Amazon Fulfillment Center is contesting an Other-than-Serious (OTS) citation with a $1,000 penalty for not meeting all of the requirements in the personal protective equipment (PPE) hazard assessment regulation – specifically 29 CFR 1910.132(d)(2). Ask almost any EHS professional and they will say, of course we know PPE hazard assessments are required. What may be forgotten, however, is the level of documentation that is also required.

Webinar: Traps in Operational Decision Making: How Cognitive Biases Put Our Decision Making at Risk

This webinar will discuss the most prevalent cognitive biases affecting how we process information and make decisions in the workplace, explain how they work, and review steps that can be taken to protect ourselves and our organizations from them.