Posts Tagged ‘Risk Mitigation’

You better watch out, you better not cry.

You better watch out I’m telling you why.

OSHA’s coming to inspect you…………someday………soon

When the Secretary of Labor, Hilda Solis, took over the helm at the Department of Labor she famously declared “OSHA’s back in the enforcement business.”  David Michaels is now the new Assistant Secretary of Labor for Occupational Safety and Health and the question is “what should employers expect?”

In September of this year, Acting Assistant Secretary of Labor for Occupational Safety and Health, Jordan Barab said “Under the new administration, OSHA is heading back to the original intent of the OSH Act. We’re back in the enforcement business and we’re back in the standards-writing business.” The fact is that OSHA has become much more aggressive in issuing citations, increasing the characterization of the citations issued, as well as introducing recommendations for higher penalties.

What sould employers expect as Michaels takes over?

• A more agressive OSHA
• More citations issues by inspectors
• Citations that are more serious with bigger penalties
• Aggressive use of various enforcement tools.  For example, employers with multiple locations and who are part of larger corporate families should expect that OSHA will attempt to use its Enhanced Enforcement Program to attempt to issue more significant citations and penalties.

Given Mr. Michaels’s background, it would also not be surprising if OSHA were to increase the number of inspections that involve industrial hygiene and health issues with the corresponding increase in the number of citations based on health standards. Health-based programs such as respiratory protection, chemical hazard communication, and bloodborne pathogens will likely be targeted. There have also been indications that OSHA will increase its efforts to investigate and issue “ergonomics” citations and OSHA may attempt to promulgate an ergonomics standard.

Internal and outside audits of OSHA compliance can be an effective way of measuring current performance and ensuring sustained compliance in the future. Management commitment to OSHA compliance, an effective and up-to-date safety and health program, employee training, and audit trails that prove proper equipment is being provided and maintained are critical in this increased enforcement environment.

Employers should not only look to existing OSHA standards, but also consider industry standards and injury trends. Employers should also consider the role of safety committees as part of an overall compliance program and ensure that committee action or inaction is not increasing potential OSHA liabilities.

With the growing “OSHA Threat” out there, companies should ensure programs are in place to ensure they are in compliance and can show a real effort toward providing a safe working environment for their workforce.  Company executives should increase efforts to create an effective safety and health program that can withstand OSHA’s new and aggressive enforcement tactics. A critical part of this training should be training management in what to do when an OSHA inspector shows up at the door for an inspection.

The Sustainable Supply Chain Management Podcast is hosted by Dr. Dale Rogers and Curtis Greve.  This podcast is focused on sustainable supply chain management issues and best practices.

Podcast #1-Risk Management considers the many issues and complexity of risk management and what executives should consider when developing strategic plans that address risks from a strategically sustainable point of view.

Podcast #1 – Risk Management

Show Notes

Dr. Rogers has identified 13 types of risks that should be considered when developing sustainable strategic plans.   The 13 types of risks are:

1. Design
2. Financial
3. Labor
4. Reputational (headline risk)
5. Process (better process reduces Ecoli)
6. Catastrophic event risk
7. Environmental risk (Sherwin-Williams avoidance – Burroughs/Unisys)
8. Human rights
9. Supply*
10. Capacity
11. Information risk
12. Ethical
13. Equity – equitable distribution of risk

All comments on this podcast, risk management, and sustainable supply chain management are welcome and will be posted.

Anytime you run an operation, you will have issues that can bring the entire operation to a halt. The difference between the best and the rest is often not that they never have any major crises, but that they are better prepared when things do go wrong and they recover quickly.

Your tip of the week this week is to “Think Risk”. Have a meeting with your team and ask each of them to write down the top three or four things that could happen that could cause a major disruption in operations. The list will include employees getting hurt, power outages, storms, customers canceling orders or doubling orders and many other things.

Once you’ve got your list, have the team prioritize these events according to which is most likely to occur. Next, for each item on the list, assign a team member to develop a plan that will help avoid the event AND a plan to recover from such an event.

Reconvene the entire team a couple of weeks later and have each member present their plans to the rest of the group for input and approval. Once you’ve got your plans together, communicate each plan to the critical team members responsible for action.

You now have a simple, effective Risk Avoidance and Risk Mitigation Plan for your operations.