U.S. Geological Survey Manual
SM 445-2-H CHAPTER 6
Inspections and Abatement
Instruction: Changes to this chapter were made so that the requirements match the requirements in the revised Department Manual while integrating Inspection and Abatement System business practices for documentation of inspections within the U.S. Geological Survey.
1. Purpose. To specify the minimum Occupational Safety and Health Program (Program) requirements for conducting safety and health inspections of establishments and timely abatement of identified hazards for all Department of the Interior (Department or DOI) and U.S. Geological Survey (Bureau or USGS) establishments and worksites.
A. 29 CFR 1960, Subpart D, Inspection and Abatement.
B. American Society of Safety Engineers, Safety and Health for Engineers, published by Wiley-Interscience.
C. National Safety Council, Accident Prevention Manual for Business and Industry, Administration and Programs, 11th Edition.
D. ANSI/AIHA Z10-2005, American National Standard for Occupational Health and Safety Management Systems.
E. 41 CFR Parts 101-21, Federal Property Management Regulations.
A. The USGS will conduct and document inspections of all establishments under its control for safety and health compliance as required by 29 CFR 1960 Subpart D and this chapter. More frequent inspections will be conducted when there is increased risk of accidents or incidents. The USGS Program includes the following types of inspection activities:
(1) Day-to-Day Inspections. Supervisors must daily monitor conditions in the workplace to prevent injuries, occupational illnesses, and property damage accidents.
(2) Annual Inspections. All USGS workplaces must be inspected at least annually. Local field office collateral duty safety and health program coordinators accomplish this requirement by completing a self-inspection questionnaire and tracking identified non-compliance findings until corrected within the USGS Inspection and Abatement System (IAS).
(3) External and Unannounced Inspections. External safety and health inspections are conducted by USGS headquarters and regional full-time safety and health staff, trained in hazard recognition and safety and health inspection procedures. These inspections are also documented within IAS. A representative number of unannounced external inspections of selected local field offices will be conducted by regional full-time safety and health staff to determine overall Program effectiveness and to ensure the proper identification and abatement of locally identified hazardous conditions. The USGS does not conduct unannounced audits which can be counterproductive to the culture we are trying to establish within the bureau. The USGS meets the intent of unannounced audits through random sampling of field programs during the program evaluation process. Field audit locations are included in program evaluations based on auditor review of historical performance metrics and IAS inspection data. An opportunity shall be provided for participation by a representative of the workplace/facility manager and an employee representative for all external inspections. The 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 will be inspected by full-time or collateral duty safety and health professionals or other qualified person(s), for unsafe or unhealthful conditions and compliance with all applicable standards, codes, and requirements. Based on the inspection findings, the inspector will recommend occupancy of the space or identify corrective actions needed to bring the space into a safe and healthful condition before occupancy. Issues not resolved locally should be directed to the appropriate regional safety and health staff, regional office, or the General Services Administration (GSA).
B. Annual and external inspections will be conducted by persons who are trained in hazard recognition and safety and health inspection procedures. Safety and health specialists, as defined in 29 CFR 1960.2(s), with experience and/or up-to-date training in occupational safety and health hazard recognition and evaluation, meet the qualifications of safety and health inspectors. For those working environments where there are less complex hazards, such safety and health specializations as cited above may not be required, but inspectors, such as collateral duty safety program coordinators or facility managers, shall have sufficient documented training and/or experience in the safety and health hazards of the workplace involved to recognize and evaluate those particular hazards and to suggest general abatement procedures.
C. The USGS requires persons conducting safety and health inspections 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 management and employees of imminent danger conditions.
(6) Take environmental samples, 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 appropriate level(s) of management and employee representative(s) to disclose the findings of the inspection and recommend abatement measures. The management and employee representative(s) will be afforded an opportunity to bring other information to the attention of the inspector regarding unsafe or unhealthful conditions in the workplace.
E. If an imminent danger condition is found, the management official in charge will initiate corrective/protective action immediately and, if necessary, stop the operation and/or evacuate the area, except for those needed to abate the condition.
F. Within 15 calendar days of completing a formal inspection (30 calendar days for items dealing with health), a written "Notice of Unsafe or Unhealthful Condition" (Notice) will be transmitted by the inspector to the site supervisor and conspicuously posted at or near each place a hazardous working condition exists, if practical, until the condition is abated or for three working days, whichever is longer. If not practical, the Notice will be posted where it is readily observable by all affected employees. For USGS purposes, the Notice will be the posting or making available to affected personnel the list of open findings within IAS. This list details all findings and/or unsafe or unhealthful condition(s), inclusive of the information contained in paragraph G below or a “Report of Unsafe or Unhealthful Condition” (USGS 445-2-H, Chapter 8), as applicable.
G. The Notice will contain the following minimum information and be provided to the appropriate levels of management and 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) Reference to applicable safety or health standards.
(4) Establishment of a reasonable time for abatement of the hazard.
(5) Risk Assessment Codes (RAC) are assigned by the inspector to each hazard to assist management with prioritization of resources to abate the most critical hazardous deficiencies. The RAC assigned to each hazard is an expression of risk, combining the severity and the probability of occurrence. The RAC criteria and definitions are detailed in Appendix A.
H. Abatement of Inspection Findings. Collateral duty safety program coordinators, or other local designee(s) with access to IAS, are responsible for coordination with respective local managers and supervisors to obtain proposed or final corrective actions for each deficiency and then document the status within IAS every 90 days until all inspection findings are abated.
I. Local management shall be responsible for quarterly review of all open inspection findings and Notices within the local abatement log within IAS. A printout of the local IAS abatement log will be provided quarterly to the local safety and health committee and employees' representative(s), as applicable. Bureau and regional safety managers shall use the IAS report function to provide respective management and committees with a quarterly status of all open IAS findings.
J. If abatement of a hazardous condition is not within the authority and resources of the organization, local management will:
(1) Inform and protect potentially affected employees.
(2) Inform and request assistance from the next higher management level in the organization and their respective safety staff, e.g., Office of Regional Services or Associate Director for Administrative Policy and Services.
(3) Coordinate, when necessary, with the Federal lessor agency if applicable, e.g., GSA, to secure abatement as specified in 29 CFR Part 1960, Subpart E, and 41 CFR Parts 101-21. Prepare and send Form 386, Quality Deficiency Report, when appropriate.
(4) Facility-related hazardous conditions above $25,000, identified within IAS and outside the financial resources of the cost center, should be placed on the regional listing of deferred maintenance projects, prioritized using Appendix A. Upon such conditions being formally incorporated within the USGS 5-Year Deferred Maintenance Plan, the finding within IAS may be closed by cross-referencing the deferred maintenance entry in the IAS corrective action plan.
K. The Occupational Safety and Health Administration (OSHA), DOI, and USGS safety and health professionals will have right of entry without delay, at reasonable times, to any facility, construction site, or other workplace to perform an inspection. They will 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 1960.31).
(1) If an inspector from OSHA arrives to conduct an inspection of a USGS establishment, the local collateral duty safety program coordinator will be notified immediately so he/she can accompany the OSHA inspector. The local collateral duty safety program coordinator shall notify the respective regional safety manager. The OSHA inspection findings, recommendations, and abatement actions will be documented within IAS, with reports communicated to the Bureau Safety and Health Management Branch, through the respective Office of Regional Services.
A. Heads of Bureaus and Offices/Designated Agency Safety and Health Official.
(1) Ensure satisfactory completion of the safety and health program inspections for all locations annually in accordance with this chapter.
(2) Annually review abatement plans and reports for unsafe or unhealthful conditions of national significance and reporting issues to the DOI Office of Occupational Health and Safety.
(3) Provide personnel and financial resources, as needed, to address abatement of findings and facilitate successful completion of the inspection process inclusive of continuous compliance improvement from year-to-year.
B. Bureau Occupational Safety and Health Program Manager.
(1) Provides Bureau safety and health inspection oversight to ensure that an effective Bureau process is in place for the identification, evaluation, and control of occupational safety and health hazards, where applicable.
(2) Monitors inspections to ensure all locations are inspected by September 30 of each fiscal year, and external inspections are conducted, as appropriate.
(3) Develops and maintains IAS to meet finding/deficiency tracking and abatement requirements for annual action plans (USGS 445-2-H, Chapter 3), program evaluations (USGS 445-2-H, Chapter 5), and compliance inspections (USGS 445-2-H, Chapter 6).
(4) Develops and incorporates standardized inspection checklists and field tools for regional and field use in meeting self-conducted and external inspection requirements within IAS.
(5) Develops IAS reports for Bureau, regional, and local tracking of unabated inspection deficiencies and management review for appropriateness and timeliness of corrective actions.
(6) Coordinates with the headquarters Office of Management Services, Facilities Management Branch, annually to review and incorporate IAS facility-related safety and health deficiencies into the local deferred maintenance plan, as appropriate.
(7) Provides the Executive Leadership Team with an annual analysis of Bureau inspection findings and deficiencies via integration into the USGS safety and health annual report, as appropriate.
(8) Establishes and publishes a formal schedule for Bureau and regional safety and health inspections conducted within the Bureau based on high-risk activities, high-rate accident statistics, occupational hazards, past Program history, personnel turnover, amount of
time since last formal review, etc., in order to eliminate duplication of effort and to ensure the most effective allocation of resources.
(9) Supports full-time and collateral duty safety and health staff through training that incorporates the inspection process and provides subject personnel with the ability to recognize safety and health hazards through the conduct of workplace inspections.
(10) Conducts National Center facility compliance inspections of non-laboratory space every 3 years and documents within IAS.
B. Regional Occupational Safety and Health Program Managers.
(1) Provide region-wide safety and health Program inspection oversight of all organizations within their respective geographical boundaries to ensure that an effective process is in place for the identification, evaluation, and control of occupational safety and health hazards.
(2) Establish and publish a formal schedule for regional safety and health inspections conducted within the region, inclusive of those conducted by the regional safety officers, for local field offices, based on high-risk activities, high-rate accident statistics, occupational hazards, past Program history, personnel turnover, amount of time since last formal review, etc., in order to eliminate duplication of effort and ensure the most effective allocation of resources. All external safety and health compliance inspections shall be documented within IAS.
(3) Conduct annual safety and health compliance self-inspections for their regions, documenting within IAS, and coordinating with respective management to close all findings.
(4) Review IAS abatement logs and associated reports, and communicate information, to respective regional management, as needed, to ensure appropriateness and timeliness of corrective actions.
(5) Coordinate with respective facilities management office annually to review and incorporate IAS facility-related safety and health deficiencies into the local deferred maintenance plan, as appropriate.
(6) Conduct a trend analysis of region-wide inspection findings and deficiencies and develop regional initiatives to address those common to the majority of field locations.
(7) Support USGS regional and local safety and health staff, e.g., regional safety officers and collateral duty safety program coordinators, through IAS training that incorporates the inspection process and provides subject personnel with the ability to recognize safety and health hazards through the conduct of workplace inspections.
(8) Assist managers in integrating safety and health deficiencies into the regional deferred maintenance plan, as appropriate.
C. Regional Area Safety and Health Officers.
(1) Provide inspection program oversight of all organizations within their respective geographical boundaries 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 of science programs in IAS to ensure that all locations within their geographic area of responsibility are informally inspected annually and follow up as appropriate for timely closure of field-level deficiencies and/or updated status reports.
(3) Establish a formal schedule for regional safety and health inspections conducted within the respective regional geographic area, based on high-risk activities, high-rate accident statistics, occupational hazards, past program history, personnel turnover, amount of time since last formal review, etc., in order to eliminate duplication of effort and ensure the most effective allocation of resources.
(4) Document external field organization inspections within their geographic area of responsibility within IAS.
(5) Review IAS reports and abatement logs and communicate information to respective regional management, as needed, to ensure appropriateness and timeliness of corrective actions.
(6) Coordinate with Office of Regional Services/Office of Management Services/Space and Facilities Management annually to review and incorporate IAS facility-related safety and health deficiencies into the local deferred maintenance plan, as appropriate.
(8) Conduct a trend analysis of regional geographic area inspection findings and deficiencies and develop initiatives to address those common to the majority of subordinate field locations.
(9) Support local safety and health staff, e.g., collateral duty safety program coordinators, through IAS training that incorporates the inspection process and provides subject personnel with the ability to recognize safety and health hazards through the conduct of workplace inspections.
(10) Assist science center managers in integrating safety and health deficiencies into the local deferred maintenance plan, as appropriate.
D. Organizational Management.
(1) Ensures annual completion of the respective self-inspections by September 30 of each fiscal year.
(2) Annually reviews organizational action plans (abatement logs) and IAS reports and provides personnel and financial resources, as needed, to address abatement of findings and facilitate continuous compliance improvement from year to year.
E. Collateral Duty Safety Program Coordinators.
(1) Coordinate the establishment of a workplace inspection program using IAS to effectively identify, document, and track 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 should be surveyed more frequently.
(2) Provide guidance and assistance to field location line managers and supervisors to comply with safety and health program inspection requirements.
(3) Coordinate the conduct of annual local field-level safety and health compliance self-inspections to include all subordinate field locations with supervisors, managers, and other collateral duty staff, e.g., local firearms and watercraft instructors and chemical hygiene officers.
Local field-level organizations are exempt from this requirement if they have undergone an “external” review by the Bureau or regional safety managers or regional safety officer during the fiscal year.
(4) Coordinate the documentation of local field-level facility inspections findings and associated corrective actions in IAS, as appropriate, following up on local abatement logs to ensure that corrective actions are documented and/or status reports updated within IAS every 90 days.
(5) Coordinate with local management and administrative staff to incorporate IAS facility-related safety and health deficiencies above $25,000 into the local and regional deferred maintenance plan, as appropriate.
/s/ Karen D. Baker 10/6/09
Karen D. Baker Date
Associate Director for Administrative Policy and Services