OSHA uses "performance based" standards for its enforcement of safety regulations. The best program on paper will mean nothing if your Employee(s) cannot do the right thing or do not know where to get information. Whether your Employee(s) can answer questions correctly (or not) is the test OSHA inspectors use to evaluate your compliance with OSHA rules. 31a. Please show me the MSDS for ______ (name a product) ______________.
Did the Employee(s) answer: "What's an MSDS?"
31b. Did the Employee(s) know where the MSDS’s are kept?
31c. Did it take less than 5 minutes for the Employee(s) to find the correct MSDS? 29 CFR 1910.1200 Employee(s) should know what an MSDS is and be able to locate a specific one in less that 5 minutes. MSDS’s should be indexed and stored in an organized fashion.
32a. When were you last trained on safety issues?
Did the Employee(s) say "I don't remember" or "Never"?
32b. Has training been in the last year?
29 CFR 1910.1200 states that: "employers shall provide information and training on hazardous chemicals at the time of their initial assignment and whenever a new hazard is introduced into their work area." Some states also specifically require annual retraining.
33. If you had to evacuate the building where would you go for a head count?
Did the Employee(s) know a pre-determined specific place? 29 CFR 1910.38 requires that emergency contingency plans specify the means of accounting for all Employee(s) after an evacuation of the facility.