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240 FW 5
Safety and Occupational Health Inspections

Supersedes 240 FW 5, FWM 410, 10/30/02

Date:  October 18, 2013

Series: Occupational Safety and Health

Part 240: Safety Program

Originating Office: Division of Safety and Health

 

 

PDF Version


                                                             TABLE OF CONTENTS

TOPIC                              

Sections

Overview: Purpose, Scope, Authorities, and Responsibilities

5.1 What is the purpose of this chapter?
5.2 What is the scope of this chapter?
5.3 What are the authorities for the inspection program?

5.4 What is the Service’s overall policy?
5.5 What are the primary responsibilities associated with this chapter?

Inspection Requirements—Annual and Periodic

5.6 What are the requirements for conducting annual safety and occupational health inspections?
5.7 What should Project Leaders/supervisors expect from a Regional Safety Office evaluation of the facility's safety and occupational health program?

5.1 What is the purpose of this chapter? This chapter establishes procedures and responsibilities for conducting safety and occupational health inspections at U.S. Fish and Wildlife Service (Service) facilities and correcting any deficiencies.

5.2 What is the scope of this chapter? This chapter applies to all Service facilities.

5.3 What are the authorities for the inspection program?

A. Occupational Safety and Health Act (OSHA) Federal Agency Safety Programs and Responsibilities (P.L. 91-596, Sec. 19).

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

C. Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters, Inspection and Abatement (29 CFR 1960, Subpart D).

D. 485 DM 6, Inspections and Abatements.

5.4 What is the Service’s overall policy? It is our policy to conduct annual safety and occupational health inspections and more comprehensive, periodic inspections at all of our facilities to ensure a safe environment for our employees and the visiting public and to identify and correct deficiencies as early as possible.

5.5 What are the primary responsibilities associated with this chapter? Table 5-1 shows who is responsible for the Service safety and occupational health inspection program.

Table 5-1: Responsibilities for the Safety and Occupational Health Inspection Program

This official…                  

Is responsible for…

A. The Director

 

(1) Ensuring that the Service maintains an effective and comprehensive safety and occupational health program, and

(2) Approving or declining to approve our safety and occupational health inspection policy.

B. The Assistant Director - Business Management and Operations

 

(1) Monitoring the effectiveness and recommending improvements to the required safety and occupational health inspection program, and

(2) Providing sufficient support and resources to the Chief, Division of Safety and Health, to ensure that the Chief can accomplish program goals.

C. Regional Directors


(1) Ensuring that there are sufficient resources and support in place to implement this policy within their areas of responsibility,

(2) Ensuring that Project Leaders and supervisors within the Regions take appropriate action to correct safety and occupational health deficiencies within the timeframes in Table 5-2, and

 

(3) Ensuring qualified employees inspect facilities and operations for compliance with the safety policies in Parts 240-244 of the Service Manual.

D. The Chief, Division of Safety and Health

 

(1) Revising and updating this chapter, as necessary, and

 

(2) Interpreting the requirements in this chapter and resolving Servicewide issues and questions about the policy.

E. Regional Safety Managers

 

(1) Advising Project Leaders, supervisors, Collateral Duty Safety Officers (CDSO), and employees on the implementation of the safety and occupational health inspection program in their Regions;

(2) Interpreting program requirements and resolving Regionwide issues and questions;

 

(3) Establishing a timeframe for facilities and field stations to have their respective documented annual safety and occupational health inspections completed and reported to the Regional Safety Office;

 

(4) Establishing a schedule for the Regional Safety Office to perform periodic, comprehensive safety program evaluations and inspections at field stations and facilities;

(5) Coordinating with Regional Asset Managers to ensure safety deficiencies are tracked by Risk Assessment Code in the Service Maintenance Management System (if the items are appropriate for entry in the 5-year Deferred Maintenance and Capital Improvement Plan);

(6) Providing technical assistance as requested to Project Leaders, supervisors, and CDSOs to identify and assess safety and occupational health hazards and appropriate corrective actions; and

(7) Sending copies of any Occupational Safety and Health Administration (OSHA) written reports or Notices of Violation issued to a Service facility within their Region to the Chief, Division of Safety and Health.

F. Regional Asset Managers

 

Coordinating with Regional Safety Managers to track safety deficiencies by Risk Assessment Codes in the Service Maintenance Management System. (They only do this for those items appropriate for entry in the 5-year Deferred Maintenance and Capital Improvement Plan.)

 

G. Project Leaders/ Supervisors

(1) Continually monitoring operations, facilities, and equipment to ensure employees are safe from recognized hazards and to prevent injuries, occupational illness, and property damage accidents;

(2) Ensuring a qualified individual conducts an annual safety and health inspection and documents the findings in a written report;

(3) Signing and dating annual inspection reports to indicate that they have reviewed them;

(4) Keeping annual inspection reports and any corrective actions on file at the office or field station for a minimum of 5 years, and providing them to the Regional Safety Office, if requested;

(5) Correcting safety and occupational health hazards as quickly as possible and within the timeframes outlined in Table 5-2, and documenting those corrective actions;

(6) Developing a Hazard Abatement Plan (management action plan) for hazards that cannot be corrected within 30 days (see section 5.6B(3)); and

(7) Sending OSHA written reports or Notices of Violation that are issued within the Project Leader’s/supervisor’s area of responsibility to the Regional Safety Manager as soon as they are received.

H. Collateral Duty Safety Officers

(1) Complying with Service policy in 240 FW 2, Collateral Duty Safety Officer, and

(2) When requested by the Project Leader/supervisor, conducting and documenting an annual safety and occupational health inspection.

I. Employees

(1) Reporting safety and occupational health hazards or concerns to their immediate supervisors, and

(2) Cooperating during evaluations and inspections and with implementing corrective actions.

5.6 What are the requirements for conducting annual safety and occupational health inspections? OSHA requires annual completion of a documented safety and occupational health inspection at all of our facilities.

A. Inspector Training/Experience:
Project Leaders and supervisors must ensure that a qualified person conducts the annual safety and occupational health inspection for the Service facility(ies) and operation(s) for which the Project Leader or supervisor is responsible. If a facility has a CDSO, then he/she should either conduct or participate in the inspection process. In some offices (e.g., Regional offices, Headquarters, and the National Conservation Training Center), the CDSO’s responsibilities may cross program divisions, so those facilities’ Station Safety Plans must describe who conducts and reviews annual inspections.

(1) The inspector must have received suitable training in hazard recognition and safety and occupational health inspection procedures and have the knowledge/skills to recommend corrective actions.  

(2) Training must include, at a minimum, the training in 240 FW 2 for CDSOs. Contact your Regional Safety Manager for specific guidance.

B. Inspection Results: The results of the annual inspection must be put in writing along with documented corrective actions taken or planned. The Project Leader or supervisor must sign and date inspection reports to show that he/she reviewed them. They must also ensure that copies of the reports are kept on file at the office/field station and are given to the Regional office, if requested.

(1) If a safety or occupational health hazard is found during an inspection that could cause death or serious physical harm, the Project Leader or supervisor must take immediate corrective or preventive action, and if necessary, stop the operation or evacuate the area.

(2) The inspector must assign a Risk Assessment Code (RAC) to hazards he/she identifies. The RAC is a measurement of the likelihood (probability) and the consequences (severity) of a particular hazard. See Exhibit 1 for how to assign a RAC to a hazard. All hazards identified must have a RAC rating of 1 to 5.

(a) The use of RACs helps management prioritize resources to abate the most critical hazards or deficiencies on a “worst-first” basis.

(b) The RAC is an expression of risk, combining the likelihood and consequences of a hazardous condition that would result in an accident, illness, or injury.

(c) The RACs and the timeframes for abatement are in Table 5-2. We explain the steps for determining the appropriate RAC for a hazard in Exhibit 1. Regions may choose to assign more stringent timeframes for abating hazards than those in Table 5-2. 

Table 5-2: Risk Assessment Code (RAC) Ratings
 (Any hazard that cannot be corrected within 30 days requires a Hazard Abatement Plan; see 5.6B(3)).

                      
                                   RAC     

                   
              Initial Abatement Timeframe

                              1  Critical
Represents an immediate danger to life, health, property, or infrastructure and requires emergency correction or control of the hazard to a lower level of risk.

As soon as possible within that work shift. 

                               2  Serious
Represents a high level of threat to life, health, property, or infrastructure and requires hazard correction or control of the hazard to a lower level of risk as soon as possible.

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

                                 3  Moderate
Represents a medium level of risk to life, health, property, or infrastructure, with correction planned and completed, or hazard controlled to a lower level of risk.

Within 12 months.

                                 4  Minor
Represents a low level risk, with correction planned and completed, or hazard controlled to a lower level of risk.

Within one budget cycle (no longer than 2 years).

                               5  Negligible
Represents the lowest level risk and is considered minor. The correction of these risks can be planned in out-years.

Incorporate abatement into the 5-year plan.

(3) The Project Leader or supervisor must ensure all hazards identified are corrected in order of priority within 30 days. If there are any hazards that cannot be or will not be corrected within 30 days, the Project Leader or supervisor must develop a short but concise Hazard Abatement Plan (management action plan) that lists the steps taken to temporarily alleviate the hazard to employees, and those they will take to permanently correct it. They also must initiate a request for additional resources when necessary to correct the hazard.

C. Ongoing Monitoring and New Facilities:

(1) The requirement for an annual safety inspection does not relieve the Project Leader or supervisor of the responsibility of continually monitoring performance and operations to ensure employees are safe on the job.

(2) Before facilities are occupied by Service employees or members of the public, a safety and health professional or other qualified person (e.g., project engineer, architect, fire safety officer) must conduct a pre-occupancy inspection for safety and health issues as either a separate activity or as part of a final inspection (this applies to newly built structures, facilities newly obtained by the Service, and to major renovation projects). The inspector must document findings and report them to the Regional Safety Office. Based on the inspection findings, the responsible inspector will recommend occupancy of the space or identify corrective actions needed to bring the space into a safe and healthful condition before it is occupied.

D. When Others (i.e., from outside the facility) Conduct the Annual Inspection:

(1) Safety and health officials from OSHA, the Department of the Interior, and the Service have the right of entry without delay, at reasonable times, to any facility, construction site, or other Service workplace to perform an inspection. They also have the right to inspect any item or place within the workplace, and to question any manager, employee, or visitor. For inspections of Government quarters, we should try to give the resident(s) advance notice of inspections whenever possible.

(2) If OSHA personnel arrive to conduct an inspection, the Project Leader or other staff must immediately contact the Regional Safety Office, who will notify the Chief, Division of Safety and Health. The Project Leader must send a copy of the OSHA written report he/she receives, and a copy of the formal response to the report he/she completes to the Regional Safety Manager. The Regional Safety Manager must provide any OSHA written report or Notice of Violation to the Chief, Division of Safety and Health. The Chief distributes these reports to the other Regions to keep them informed, as appropriate.

5.7 What should Project Leaders/supervisors expect from a Regional Safety Office evaluation of the facility's safety and occupational health program?

A. All facilities undergo an overall safety and occupational health evaluation that the Regional Safety Office schedules and conducts. The purpose of the evaluation is to determine to what extent the Project Leader or supervisor has implemented a safety and occupational health program that meets OSHA, Departmental, and Service requirements. Although the Region usually gives prior notice about the evaluation, they don’t have to. In some cases, you may be asked to complete a Pre-Visit Questionnaire (FWS Form 3-2237) or prepare other documentation prior to the visit. When possible, Regions schedule these evaluations so they are conducted at the same time as environmental program inspections.

B. Regional Safety Office personnel initially meet with the Project Leader/supervisor and the CDSO to go over the evaluation process and determine if there are any particular safety issues of concern. The evaluation is detailed enough to determine safety and health program effectiveness. This may include a review of any combination of the following:

(1) OSHA written programs (OSHA requires field station-specific written programs be developed to comply with regulatory standards when tasks, associated hazards, and level of exposure warrant them. Examples of activities or circumstances requiring written programs include: confined spaces, bloodborne pathogens, hazard communication, lock-out /tag-out, and respiratory protection);

(2) Training records;

(3) Accident reports;

(4) Annual inspection reports;

(5) Hazard Abatement Plans (management action plans);

(6) Safety certification statements, if required in the Region;

(7) Other safety and health program-related items; and

(8) Physical inspection of the facility.

C. At the end of the visit, Regional Safety Office personnel must hold a closeout meeting to discuss their findings. The Regional Safety Office must send a written report documenting the findings and any recommended corrective actions to the Project Leader/supervisor within 30 calendar days. The Project Leaders and other managers are responsible for correcting deficiencies as described in this policy.

 

For more information about this policy, contact the Division of Safety and Health. For more information about this Web site, contact Krista Bibb in the Division of Policy and Directives Management.

 

 

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