A proposed rule-making from the Department of Labor is intended to clarify employee authorized third-party attendance if the compliance officer determines the third party is reasonably necessary to conduct an effective and thorough safety inspection.
The proposed changes also clarify that third-party representatives are not limited to industrial hygienists or safety engineers, two examples included in the existing regulation. Third-party representatives may be reasonably necessary because they have skills, knowledge or experience that may help inform the compliance officer’s inspection. This information may include experience with particular hazards, workplace conditions, or language skills that can improve communications between OSHA representatives and workers.
Worker participation has always been a key element of workplace safety and health inspections. In fact, to improve health and safety at your workplace, this is essential to remember. Employees should be represented to ensure an effective assessment and third-party representation is often necessary to improve the process.
Don’t just have someone walk around looking at the physical environment. Identifying hazards and risks requires much more! It’s essential to,
- Observe tasks being performed,
- Talk to employees,
- Ask employees and experts about the hazards,
- Discuss methods to correct hazards and prevent risks
We always take a holistic approach during safety walkthroughs or before implementing a service requested to capture all elements and effectively plan the safety program. Actually, we recently experienced the need for an authorized third-party during a recent site walkthrough. We requested a translator to improve direct communication with employees. The knowledge gained and the solutions gleaned from the employees were the keys to correcting issues and ensuring a safe and healthy work environment.
For more information, check the Federal Register. Please also contact Dimensions to discuss how our approach may be of value to your safety and health program.