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Tell Them Something…and Then Document It

Posted by Gary Finch on December 1, 2015

  If you like that heading, you can credit an OSHA inspector from the Austin, TX office. It was not a wisecrack. It was not a joke. He was just telling it real. I had questioned the inspector on an element of COF 1910.157. The standard is about the Incipient Stage of Fire Extinguisher Education. This is not a standard where one size fits everyone.

  For example, businesses that do welding, cutting and other hot work are required to set-up Fire Brigades and have extensive training requirements. At the other end of the spectrum, you will find the one hour photo shop, your neighborhood insurance office, and your local funeral home. We have very few requirements. It is exactly those types of jobs that require the least from us that we are most likely to trip over.

  The number one citation among funeral homes this past year was a tie between formaldehyde and respiratory protection. Citations for emergency exit routes, emergency action plans, and fire extinguishers also make the annual list. It surprises me and I’m fairly certain it surprises most of you.

  It is especially surprising to workplaces that have a motivated safety officer. They rework the bloodborne pathogen program and make sure everyone has their hepatitis B vaccinations and their current training. They have presented the new GSA Hazard Communications Program to the entire workplace. Their formaldehyde monitoring is done. They feel the employees are safe, and they also feel their employer is safe from any OSHA citations. But that is an illusion. Those three standards, Bloodborne Pathogen, Formaldehyde and Hazard Communications total less than half of citations given to funeral homes.

  A local safety officer would be well served in those collateral duties if he or she were to make a list. Who is authorized to climb a ladder? Who can enter the attic or other confined spaces? Which employees are authorized to operate a fire extinguisher? Keep these lists current when new people are hired or leave.

  You should never underestimate the importance of documentation. In a small business (like most funeral homes), the employees that are authorized to operate fire extinguishers must take part in an annual training program. It does not have to include hands on fire extinguisher operation. That is only required for initial training. What about those other employees? What about those that didn’t make the list. That’s what I asked the inspector.

  Oh, just tell them which way to go if there is a fire. And remind them where to go once they are outside. It’s a basic one minute training program. AND DOCUMENT IT! I believe “Failure to Document” is responsible for at least half of OSHA citations. And the more insignificant the program, the more frequent is the failure to document. This next year, make an effort to document the things you do.


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