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U.S. Geological Survey Manual

SM 445-2-H CHAPTER 6

Inspections and Abatement

Instruction:  Changes to this chapter were made to reflect changes made to the organizational structure during Bureau realignment.

1.  Purpose/Scope.  This chapter specifies the minimum Occupational Safety and Health Program (Program) requirements for conducting safety and health inspections of establishments and the timely abatement of identified hazards for all U.S. Geological Survey (USGS) establishments and worksites.

2.  Authorities/References.

A.  Public Law 91–596, Occupational Safety and Health Act of 1970, (the Act), Section 19.

B.  Executive Order 12196, Occupational Safety and Health Programs for Federal Employees.

C.  29 Code of Federal Regulations (CFR), Part 1960, Subpart D, Inspection and Abatement (1960.25 – 1960.31).

D.  29 CFR 1960.34 General Provisions (General Services Administration).

E.  Roger L. Brauer, Safety and Health for Engineers, current edition,published by John Wiley and Sons.

F.  National Safety Council, Accident Prevention Manual for Business and Industry, Administration and Programs, current edition.

G.  American National Standards Institute (ANSI)/American Industrial Hygiene Association (AIHA), Z10 (current version), Occupational Health and Safety Management Systems.

H.  41 CFR Part 102–74.360 What are the specific accident and fire prevention responsibilities of occupant agencies?

I.  485 DM 6, Inspections and Abatement.

J.  SM 445-2-H Chapter 8, Employee Reports of Unsafe Conditions and Allegations of Reprisal.

3.  Requirements.

A.  The Bureau shall conduct and document inspections of all areas and operations of establishments under its control for occupational safety and health compliance at least annually as required by 29 CFR 1960 Subpart D and this chapter.  More frequent inspections shall be conducted when there is an increased risk of accidents or incidents.  The USGS Program includes the following types of inspection activities:

(1)  Day-to-Day Inspections.  Supervisors shall monitor conditions daily in the workplace to prevent injuries, occupational illnesses, and accidents that cause property damage.

(2)  Annual Inspections.  All workplaces and areas and operations shall be inspected at least annually.  Collateral Duty Safety Program Coordinators (CDSPCs) accomplish this requirement by conducting a walk around of all local facilities/operations using appropriate checklists and a self-inspection questionnaire.  All identified noncompliant conditions (findings) shall be documented in the Inspection and Abatement System (IAS) until they are corrected.

(3)  External and Unannounced Inspections.  

(a)  External occupational safety and health inspections are conducted by headquarters and regional full-time occupational safety and health staffs who are trained in hazard recognition and occupational safety and health inspection procedures.  The schedule for inspections and evaluations shall be based on high-risk activities, high rates of accidents, occupational hazards, past Program history, personnel turnover, the amount of time since the last formal review, and similar criteria.  External Specialized Safety Program inspections planned for the upcoming fiscal year shall be scheduled within the IAS no later than September 30 of the current calendar year.  Results of external inspections shall be documented in IAS.  

(b)  A reasonable number of unannounced external inspections of selected local field offices may be conducted by headquarters and regional full-time occupational safety and health staff to determine the overall Program effectiveness and to ensure the proper identification and abatement of locally identified hazardous conditions.  

(c)  For all external inspections, an opportunity shall be provided for an employee representative and either a representative of the workplace or a facility manager to participate in the inspection.  

(d)  The lead occupational safety and health inspector may deny the right of accompaniment to any person whose participation interferes with the inspection.

(4)  Preoccupancy Inspections.  All newly constructed or renovated space shall be inspected by full-time or collateral duty occupational safety and health professionals or other qualified person(s) for unsafe or unhealthful conditions and compliance with all applicable standards, codes, and requirements.  On the basis of the inspection findings, the inspector shall either recommend occupancy of the space or identify corrective actions needed to bring the space into a safe and healthful condition before occupancy.  The issues that cannot be resolved locally should be directed to the appropriate Office of Management Services (OMS) or regional occupational safety and health staff or to the General Services Administration.

B.  Annual and external inspections shall be conducted by persons who are trained in hazard recognition and occupational safety and health inspection procedures.  As defined in 29 CFR 1960.25 and 1960.2(s), occupational safety and health specialists in the 0018/0690 career series having experience and/or up-to-date training in occupational safety and health hazard recognition and evaluation meet the qualifications of occupational safety and health inspectors.  For those working environments where there are less complex hazards, inspectors (such as CDSPCs or facility managers) shall have documented training and/or experience in the safety and health hazards of the workplace that are sufficient to recognize and evaluate those particular hazards and to suggest general abatement procedures.  Within the USGS, completion of the twenty-four USGS Occupational Safety and Health Administration (OSHA) Equivalent 6000 Courses within DOI LEARN establishes the minimum educational requirements for the conduct of such workplaces, to be supplemented by additional on-the-job training from headquarter and regional occupational safety and health staff and formal training outlined in the Department of the Interior (DOI) Safety and Health Training, Technical Skills and Abilities for Collateral Duty and Full-Time Safety Personnel Handbook.  

C.  Inspectors conducting occupational safety and health inspections are required to:

(1)  Have the necessary equipment to conduct the inspection.

(2)  Examine appropriate accident records and previous inspection reports.

(3)  Hold an opening conference with the establishment manager.

(4)  Consult with employees on matters of safety and health.

(5)  Inform managers and employees of imminently dangerous conditions.

(6)  Conduct personal monitoring (sampling) of employee work environments, where appropriate.

(7)  Comply with safety rules and practices.

(8)  Take or obtain photographs, where appropriate.

(9)  Avoid unreasonable disruption of the operation.

(10)  Hold a closing conference with the representative from the appropriate level(s) of management and the employees in order to disclose the findings of the inspection and recommend abatement measures.  The manager(s) and employee representative(s) shall be afforded an opportunity to bring other information to the attention of the inspector regarding unsafe or unhealthful conditions in the workplace.

D.  If an imminently dangerous condition (Risk Assessment Code 1, or RAC-1) or elevated threat to life, health, or property (RAC-2) is found, the manager in charge shall initiate corrective and/or protective action immediately and, if necessary, stop the operation and/or evacuate the area except for those employees who are assigned to abate the condition.

E.  Within 15 calendar days of completing a formal inspection (30 calendar days for health-related items), a written "Notice of Unsafe or Unhealthful Condition" (the Notice) for identified RAC-1 or RAC-2 conditions shall be transmitted by the inspector to the site supervisor and conspicuously posted at or near each place where a hazardous working condition exists, if practical, until: (1) the condition is abated or (2) for three working days, whichever is longer.  If not practical, the Notice shall be posted where it is readily observable by all affected employees.  The establishment manager shall ensure that all employees are briefed on the hazard(s) and on the steps underway to abate the condition(s).  For inspections conducted by the Bureau, the Notice that is made available to affected personnel shall consist of the printout of open findings within the IAS that relate to the unsafe or unhealthful conditions.  This printout shall detail all findings and/or unsafe or unhealthful condition(s), including the information contained in 6.3.F. below or a “Report of Unsafe or Unhealthful Condition” as described in SM 445-2-H.8, as applicable.

F.  The Notice shall contain the following minimum information and shall be provided to those at the appropriate levels of management and to the employee representative(s) participating in the inspection:

(1)  Identification of the location of the hazard.

(2)  Description of the nature and extent of the hazard.

(3)  Risk Assessment Code (RAC).  RACs are assigned by the inspectors to each hazard or deficiency that violates an authority or reference to this chapter.  RACs are used to assist management with the prioritization of resources to abate the most critical hazards or deficiencies on a “worst-first” basis.  The RAC assigned to each hazard is an expression of risk that combines the severity of the hazardous condition with the probability that it will result in an accident.  The exposure of personnel to a hazard is an integral part of the probability determination and should be considered when assessing the likelihood of a hazard resulting in an accident, injury, or illness.  The RAC criteria and definitions are detailed in the DOI Risk Assessment System in Appendix A.

(4)  Description of the mitigation control measures.

(5)  Reference to applicable safety or health standards.

(6)  Establishment of a reasonable time for abatement of the hazard.  Initial mitigation or abatement of the hazard or condition should be accomplished within the following timeframes:


RAC Code

Initial Abatement Timeframe

1

As soon as possible within that work shift

2

As soon as possible, but no later than 15 calendar days

3

Within 12 months

4

Within one budget cycle (no longer than 2 years)

5

Incorporate abatement into the 5-Year Plan

G.  The CDSPCs or other local designated persons with access to IAS are responsible for coordinating with their respective local managers and supervisors to obtain the proposed or final corrective actions for each deficiency and document the status of corrective actions in IAS every 90 days until each hazardous condition is abated.

H.  An abatement plan shall be established for all inspection findings which cannot be abated within 30 calendar days.  The plan should include an explanation for the abatement delay, proposed corrective actions, a timetable for abatement, and a summary of the interim steps that have been taken to protect personnel.  If the abatement plan changes, the supervisor shall be responsible for preparing and posting a new Notice of Hazard with updated information.  Note: The initial RAC assigned by the inspector shall remain the assigned RAC, regardless of any interim control measures and mitigation taken to reduce risk.  Use of IAS finding and tracking functions facilitates meeting the intent of this requirement.

I.  The local managers shall be responsible for the quarterly review of all open inspection findings and Notices within the local abatement log in IAS.  A printout of the local IAS abatement log shall be provided quarterly to the local occupational safety and health committee and to the employees' representative(s), as applicable.  Headquarters and regional safety staff shall use the IAS report function to provide the respective managers and committees with a quarterly status of all open findings in IAS.

J.  If the local manager does not have the authority or resources to abate the hazardous condition, he or she shall do the following:

(1)  Inform and protect potentially affected employees.

(2)  Inform and request assistance from the next highest manager in the organization and the respective safety staff; e.g., the Regional Director or Associate Director’s office, and the respective Regional Safety Manager or Headquarters occupational safety and health staff. 

(3)  When necessary, coordinate with the Federal lessor agency; e.g., the General Services Administration; to secure abatement as specified in 29 CFR Part 1960.34.

(4)  Each facility-related hazardous condition that: (a) will cost more than $25,000 to abate, (b) is identified in IAS, and (c) is outside the financial resources of the cost center, shall be incorporated in a facilities maintenance management system and prioritized using Appendix A.  Deferred maintenance project entries should be cross-referenced in IAS.

J.  OSHA, DOI, and USGS full-time occupational safety and health professionals have the right of entry without delay, at reasonable times, to any facility, construction site, or other workplace to perform an inspection.  They also have the right to inspect any item or place within the establishment and to question, privately, any employee, manager, supervisor, visitor, contractor, or concessioner associated with the establishment.  (See 29 CFR 1960.26 and 1960.31.)

K.  If an inspector from OSHA arrives to conduct an inspection, the local CDSPC will be notified immediately so that he or she can accompany the OSHA inspector.  The local CDSPC will notify the respective Regional Safety Manager or Headquarters Occupational Safety and Health Manager that an OSHA inspector is onsite.  In turn, the Regional Safety Manager notifies the Bureau OSH Program Manager.

L. The OSHA inspection shall be entered as a “Safety – Other” audit, with a copy of the OSHA report uploaded and individual OSHA findings and corresponding abatement actions documented in IAS.  

4.  Responsibilities.

A.  Director, Associate and Regional Directors, and Bureau Designated Agency Safety and Health Official.

(1)  Require compliance with occupational safety and health inspection requirements.

(2)  Assure that all subordinate locations and operations are inspected by September 30 of each fiscal year and that followup inspections are conducted as appropriate.

(3)  Ensure that assigned occupational safety and health staff are knowledgeable about the inspection process and have the ability to recognize occupational safety and health hazards.

(4)  Ensure that identified inspection findings and hazards are classified according to the DOI Risk Assessment System.

(5)  Provide personnel and financial resources, as needed, to abate hazardous conditions and to facilitate the successful completion of the inspection process, which includes continuous improvement in compliance from year to year.

B.  Chief, Office of Management Services.

(1)  Ensures the establishment of an evaluation process for assessing: (a) the effectiveness of national- and regional-level occupational safety and health inspection programs and (b) the control of occupational safety and health hazards.

(2)  Provide support services to and coordinate with Associate Directors and Regional Directors to address gaps and deficiencies identified through self and external inspections and track associated corrective actions through abatement to facilitate Program improvement.

C.  Bureau Occupational Safety and Health Program Manager.

(1)  Provides national occupational safety and health inspection oversight to ensure that an effective bureauwide process is in place for identifying, evaluating, and controlling occupational safety and health hazards, where applicable.

(2)  Monitors inspections to ensure that all organizations conduct self-inspections by September 30 of each fiscal year and that external inspections are conducted, as appropriate.

(3)  Develops and maintains the IAS in order to meet the finding or deficiency tracking and abatement requirements.

(4)  Develops and incorporates standardized inspection checklists and tools for use in meeting the self-conducted and external inspection requirements in IAS.

(5)  Develops IAS reports to facilitate national, regional, and local tracking of unabated inspection deficiencies and for use by managers in reviews of the appropriateness and timeliness of corrective actions.

(6)  Coordinates with the Office of Management Services, Facilities Management Branch, to include Condition Assessment Occupational Safety and Health findings sin IAS and reviews annually deferred maintenance projects to facilitate appropriate prioritization in accordance with the RAC criteria and definitions detailed in Appendix A.

(7)  Annually reviews abatement plans and reports for unsafe or unhealthful conditions of national significance and reports those conditions to the DOI Office of Occupational Safety and Health.

(8)  Provides the Executive Leadership Team with an annual analysis of the Bureau’s occupational safety and health inspection findings and deficiencies by integrating the analysis into the Annual Report, as appropriate.

(9)  Ensures that all external Specialized Safety Program inspections planned for the upcoming fiscal year are scheduled in IAS.

(10)  Coordinates with Specialized Safety Program Managers, Regional Safety Managers, and Associate Director points of contact, and local CDSPCs to establish and publish a formal schedule for OSH inspections conducted within the Bureau, including those conducted by the Regional Safety Managers at local field offices, in order to eliminate the duplication of effort and ensure the most effective allocation of resources.  
(11)  Ensures that all external OMS and regional occupational safety and health compliance inspections planned for the upcoming fiscal year are scheduled in IAS.

(12)  Reviews IAS abatement logs and associated reports and communicates information, as needed, to ensure appropriate and timely corrective actions.

(13)  Conducts a trend analysis of national capabilities and regional occupational safety and health inspection findings and deficiencies and develops initiatives to address common findings and deficiencies.

(14)  Supports Regional Safety Managers and national Program points of contact or CDSPCs by providing IAS training that incorporates the inspection process, thus enabling the subject personnel to recognize occupational safety and health hazards through workplace inspections.

(15)  Conducts compliance inspections of national capabilities and facilities.

D.  Regional Safety Managers.

(1)  Provide inspection program oversight of all organizations within their respective regions to ensure that an effective program is in place for the identification, evaluation, and control of occupational safety and health hazards.

(2)  Monitor self-conducted inspections in IAS to ensure that all locations within their regions are inspected annually and follow up as appropriate to ensure the timely closure of field-level deficiencies and/or to update the status of corrective actions.

(3)  Establish a formal schedule and conduct external safety and health inspections of subordinate field locations.

(4)  Document the inspections conducted at the field localities within their regions in IAS.

(5)  Review IAS reports and abatement logs and communicate the information to the respective regional and local managers, as needed, to ensure appropriate and timely corrective actions.

(8)  Conduct a trend analysis of region-wide inspection findings and deficiencies and develop initiatives to address those that are common to subordinate field locations.

(9)  Support the local CDSPCs by providing IAS training that incorporates the inspection process, thus enabling the subject personnel to recognize occupational safety and health hazards through workplace inspections.

(10)  Review condition assessment audit reports and upload occupational safety and health findings and assign RAC codes in IAS so that local cost centers can document and track abatement actions. 
E.  Center Directors/Field Office Chiefs/Program Managers.

(1)  Ensure completion of the respective occupational safety and health self-inspections of all field facilities and operations by September 30 of each fiscal year.

(2)  Annually review organizational action plans (abatement logs) and IAS reports.  Provide personnel and financial resources, as needed, to abate occupational safety and health hazards to facilitate the continuous improvement of local compliance.

(3)  Ensure that an abatement plan is established for all inspection findings which cannot be abated within 30 calendar days.

F.  Collateral Duty Safety Program Coordinators.

(1)  Conduct a workplace occupational safety and health inspection at least annually.  Use IAS to identify, document, and track occupational safety and health deficiencies until corrective action is taken either to eliminate or reduce the hazard to an acceptable level.  High-hazard workplaces or locations where there is an increased risk of accident or injury due to the nature of the operations shall be inspected more frequently.
 
(2)  Provide guidance and assistance to managers and supervisors to aid them in complying with occupational safety and health program inspection requirements.

(3)  Coordinate the annual local occupational safety and health self-inspections to include all subordinate facilities or locations with supervisors, managers, and other collateral-duty staff; e.g., local firearms and watercraft instructors and chemical hygiene officers.  Local organizations are exempt from this requirement if they are undergoing an external review by full-time national- or regional-level occupational safety and health staff during the fiscal year.

(4)  Document inspection findings and associated corrective actions in IAS, as appropriate.  Follow up on local abatement logs to ensure that corrective actions are documented and/or the status of corrective actions is updated in IAS every 90 days.

(5)  Coordinate with local managers and administrative staff to incorporate IAS and condition assessment facility-related safety and health deficiencies that will cost more than $25,000 to abate into the local and deferred maintenance plan, as appropriate.

Appendix A


Katherine McCulloch /s___________________________                9/19/14_____________
Katherine McCulloch                                                                          Date
Acting Associate Director for Administration


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