By John Gargiulo, EIA Senior Loss Prevention Specialist
I recently attended a seminar hosted by the Sacramento Valley Section of the American Industrial Hygiene Association and one of the subjects presented was titled Heat Illness Prevention Inspections Results. The speaker was Bob Senchy of Cal OSHA Enforcement.
Beyond reviewing the history of the code’s development and citations that have been issued over the past several years, Bob reviewed several of the “policies” he had gathered during his field inspections and highlighted the shortcomings of each. The common threads were:
1. The attempt of organizations to “cut and paste” and/or purchase generic Heat Illness policies and make them stand alone policies
2. The lack of any true procedures
In short, the companies secured generic policies and did not add any procedural detail to make them operational. Web based policies, those provided by consultants, or even the Cal OSHA model policy in and of itself will not meet compliance without the entity specific details of how they plan on meeting the code requirements.
As an example, many of the policies said the employer would provide water to the employees as required in the code. But, none of them stated procedurally how that would be done. Details like who would get the water on a daily basis, how they would keep it cool, who would wash and disinfect the containers and how they would do it were missing. Without this kind of detail the policies were viewed as deficient and non-compliant, leading to citation.
Anytime you encounter a requirement for a procedure, per Cal OSHA, you should have a written and living document that you can supply for review upon request.
Procedures should be in a “go to the freezer and get the box,” step-by-step format. Remember to include who is responsible for doing the work, what protective measures must be taken, and make sure to cover all the bases.
The need to include entity specific procedures is required in every industry standard and regulation that comes to mind.
We encourage you to check your policies for entity specific detail to ensure you meet or exceed Cal OSHA expectations.
Give us a call (916) 850-7300 or check us out on the EIA website for more information.
