General Plant Safety Issues Introduction

The following section addresses these areas of concern in your facility and are listed in the order of predominant OSHA violation focus: Hazard Communication Emergency Action Plan/Exits/Egress Fire Safety/Eye Washes Limited/Blocked Access to Disconnect Means Walking/Working Surfaces/Housekeeping Electrical Hazards Hoist Safety Forklift Safety (PIT) Permit-Required Confined Space Ergonomics General Programs/Documentation

Hazard Communication Purpose

1910.1200(a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training. 1910.1200(f)(7) Exemption: The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. The issue that arises when evoking this exemption is when the employees transferring (or controlling) the material turns away, goes on break or otherwise does not have full control of the container. Full control of an unlabeled container is very difficult to manage unless it is truly very small quantities and for immediate use.

Hazard Communication Concerns

Areas of concern are: Lack of numerical/pictorial labeling of individual bottles Individual containers hand labeled with cryptic information Unlabeled open 3-5 gallon buckets containing mysterious substance MSDS signs may mislead employees as to the location of the actual documents

Hazard communication is one of the most often cited violations under OSHA regardless if it is a State/Federal plan. In 2007 1910.1200 was the #1 cited violation for general industry at 5931 for a settled value of $1,218,351.00 (CCH, August 2009). XYZ Foods specific hazard communication program was not reviewed as part of this plant visit, therefore, gaps in the program are not addressed. Within the scope of this review container labeling is a issue and observed repeatedly as well as language barriers. Most preferably the numerical category provided using the NFPA 704 or the HMIS system would enhance the labeling communication as they are numerical /pictorial and easily identifiable.

Hazard Communication
1910.1200(f)(9) The employer shall ensure that labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.

MSDS

Hazard Communication Recommendations For MSDS

1. Designation of person(s) responsible for obtaining and maintaining the MSDSs; 2. How such sheets are to be maintained in the workplace (e.g., in notebooks in the work area(s) or in a computer with terminal access), and how employees can obtain access to them when they are in their work area during the work shift; 3. Procedures to follow when the MSDS is not received at the time of the first shipment; 4. For producers, procedures to update the MSDS when new and significant health information is found; and, 5. Description of alternatives to actual data sheets in the workplace, if used.

1910.1200 Appendix E

Hazard Communication Recommendations For MSDS (con)

For any safety and health program, success depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires a change in behavior. This will only occur if employers understand the program, and are committed to its success, and if employees are motivated by the people presenting the information to them.

1910.1200 Appendix E

Hazardous Communication 1910.1200 Container

Labels
LABEL TYPES

NFPA 704 Label

HMIS Label

"Hazardous chemical" means any chemical which is a physical hazard or a health hazard. 1910.1200(c)

Individual Container Labels

1910.1200(f)(5)The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: Identity of the hazardous chemical(s) contained therein; and, Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. Maintenance Room

ADD Proper LABEL

Individual Container Labels

Maintenance Room

Proper Label

Improper Label

Individual Container Labels

1910.1200(f)(5)The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: Identity of the hazardous chemical(s) contained therein; and, Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. Bakery

ADD Proper LABEL

Individual Container Labels

Appetizers USDA

ADD Proper LABEL

Although this appear to be food stuff it is possible for employees to misunderstand the contend, therefore, it is a good practice to label with material content. Exemption: 1910.1200(f)(7) The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.

Individual Container Labels

Although these labels identify the contents of the containerit is not adequate. The haz com labeling system must be uniform and be readily identified/recognized especially as XYZFoods has multiple languages spoken by employees. It s best to use a universally recognized label with pictorial display. This aligns with 1910.1200(f)(9).

Shells

Zoom Shot

Recommendations For Individual Containers & Labeling

Ensure Compliance by:
1. Designation of person(s) responsible for ensuring labeling of in-plant containers; 2. Designation of person(s) responsible for ensuring labeling of any shipped containers; 3. Description of labeling system(s) used; 4. Description of written alternatives to labeling of in-plant containers (if used); and, 5. Procedures to review and update label information when necessary.

1910.1200 Appendix E
Consider purchasing a label maker for your hazard communication individual containers as it will print numerical values for each hazard category and pictorial icon for the PPE requirement as they help to bridge the language barrier.

Individual Container Labeling

Post this Guide

Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations strategically place, including this or similar pictorial guide with an audit program and restocking activities.

Individual Container Labeling

HMIS Label

Post this Guide

Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations strategically place, including this or similar pictorial guide with an audit program and restocking activities.

Individual Container Labeling

This system uses the NFPA 704 label but can be adapted to HMIS Price (ea.) $15.39 Brand MASTER Mfr. Model # S1601

Place a stock of labels in this slot

Holes for mounting2 at the top and 2 at the bottom

Permanent Marker Fits in These Slot

Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations strategically place, including this or similar pictorial guide with an audit program and restocking activities.

Emergency Action Plan, Exits & Egress

Purpose of Emergency Action Plan (EAP), exit, & egress is to ensure safe exiting in case of an evacuation emergency. 1910.34 Most of the exit doors were appropriately marked. Exception in the ammonia room where the exits were difficult to find due to marking and the poor lighting. Additionally several of the interior doors are not identified as Not An Exit. Emergency action plans (EAP) are required for all business regardless of the size. 1910. 38 was cited as a violation 195 time for a settled value of $78,860.00. The EAP program was not reviewed as part of this plant visit, however, only three issues were observed and they were not overt. This is an area of concern due to the fact that having an issue with exiting a building may lead to a catastrophic event. Maintenance of exits is a highly cited violation with 1253 issued in 2008 at a settled value of $565,980.00. This issue is also the primary focus of NFPA Life Code 101.

EXITS, EGRESS & EMERGENCY ACTION PLAN (EAP) is an Egress/Exit? What

NFPA 101 A.3.3.161 Means of Egress. A means of egress comprises the vertical and horizontal travel and includes intervening room spaces, doorways, hallways, corridors, passageways, balconies, ramps, stairs, elevators, enclosures, lobbies, escalators, horizontal exits, courts, and yards. OSHA 1910.33 Means of Egress is the way to, through, and away from and exit.

EAP, Exits & Egress

An employer who demonstrates compliance with the exit route provisions of NFPA 101-2000, the Life Safety Code, will be deemed to be in compliance with the corresponding requirements in 1910.34, 1910.36, and 1910.37. [39 FR 23502, June 27, 1974, as amended at 45 FR 60703, Sept. 12, 1980; 53 FR 12121, Apr. 12, 1988; 67 FR 67962, Nov. 7, 2002] CFR 291910.35

Well Identified Exit

Note: 1910.37(a)(1) Exit routes must be kept free of explosive or highly flammable furnishings or other decorations.

EAP, Exits & Egress

3.3.161* Means of Egress. A continuous and unobstructed way of travel from any point in a building or structure to a public way consisting of three separate and distinct parts: (1) the exit access, (2) the exit, and (3) the exit discharge. 4.5.3.2 Unobstructed Egress. In every occupied building or structure, means of egress from all parts of the building shall be maintained free and unobstructed. Means of egress shall be accessible to the extent necessary to ensure reasonable safety for occupants having impaired mobility. NFPA 101, Life Code Safety 2009

Exit route means a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety (including refuge areas). An exit route consists of three parts: The exit access; the exit; and, the exit discharge. (An exit route includes all vertical and horizontal areas along the route.) 1910.34(c)

EAP, Exits & Egress

1910.37(b)(5) Each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar designation, or be identified by a sign indicating its actual use (e.g., closet).

Doors may be labeled as Not An Exit or be labeled with the use or purpose of the room such as closet or janitorial supplies.

EAP, Exits & Egress

Appetizer USDA Affix not An Exit to doors

EAP, Exits & Egress

Shells

Packaging

Label All Doors

EAP, Exits & Egress

Ammonia Room

Label All Doors

FIRE SAFETY & EYE WASHES

Fire Safety/Eye Washes

Fire Extinguishers The issues observed are related to the overall employees safety as it relates to OSHA General Industry standard Subpart L. At XYZ Foods the issues are: Lack of inspection/testing/maintenance of fire Lack of documentation of inspection Fire extinguishes blocked Eye Washes NFPA/ANSI/OSHA all have various conditions where eyewash (and drench showers) stations are required and likewise various standards for these safety devices. The explanation for specifics are not clearly and specifically centrally located. Regardless as XYZ Foods have eyewashes in the plant they must be maintained and managed. Fire hazards & eyewash are often cited by OSHA during inspection due to the magnitude of potential. It is extremely important to align the written program with the plant practices. For XYZs Foods this is especially true due to the multiple languages spoken by the employees. Because fire extinguishers are provided there is an assumption of safety and beyond the OSHA citation issue, having fire extinguishes that are not in readiness condition, depressurized, or the access blocked could lead to high liability results., This is highly cited by OSHA and is covered in the NFPA 10 as well as NFPA Life Code 101.

Fire Extinguishers
NFPA 10 Fire Extinguishers Overall 7.1.1 The owner or designated agent or occupant of the property in which the fire extinguishers are located shall be responsible for inspection, maintenance, and recharging. 7.1.3 Removing from service for maintenance or recharging shall be replace by a fire extinguisher suitable for the type hazard being protected and shall be at least equal rating.

NFPA Specific Inspection Examination for obvious damage, corrosion, leakage, or clogged nozzles. NFPA 10 7.2.2.2 Corrective action When a inspection of any fire extinguisher reveals deficiency in any of the conditions listed in 7.2.2.2 immediate correction action shall be taken. NFPA 10 7.2.3 Removing Removing from service for maintenance or recharging shall be replace by a fire extinguisher suitable for the type hazard being protected and shall be at least equal rating. NFPA 101 7.1.3

Fire Extinguishers & OSHA

OSHA allows a building without fire extinguishers as stated below if the EAP is to evacuate the building. However, all insurance carriers and local/state fire agencies require them in building where visitors/employees o occupants are present. OSHA goes on to state that if fire extinguishers are provided employers must train designated employees to use them. 1910.157(a) Scope and application. The requirements of this section apply to the placement, use, maintenance, and testing of portable fire extinguishers provided for the use of employees. Paragraph (d) of this section does not apply to extinguishers provided for employee use on the outside of workplace buildings or structures. Where extinguishers are provided but are not intended for employee use and the employer has an emergency action plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, then only the requirements of paragraphs (e) and (f) of this section apply. 1910.157(b)(2) Where the employer has an emergency action plan meeting the requirements of 1910.38 which designates certain employees to be the only employees authorized to use the available portable fire extinguishers, and which requires all other employees in the fire area to immediately evacuate the affected work area upon the sounding of the fire alarm, the employer is exempt from the distribution requirements in paragraph (d) of this section.

Fire Extinguisher
Unsuitable Fire Extinguisher Discharging Unit 1910.157(c)(4) The employer shall assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use. 1910.157(e)(2) Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly. (1910.157(d)(3) standpipe replacing fire extinguishers). Where required by the provisions of another section of this Code, portable fire extinguishers shall be installed, inspected, and maintained in accordance with NFPA10, Standard for Portable Fire Extinguishers. NFPA 101 9.7.4.1*

This condition was not simply a one-time occurrence, it was the general overall condition.

Fire Extinguisher
Unsuitable Fire Extinguisher Overcharging Unit

1910.157(c)(4) The employer shall assure that portable fire extinguishers are maintained in a fully charged and operable condition and kept in their designated places at all times except during use. 1910.157(e)(2) Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly. (1910.157(d)(3) standpipe replacing fire extinguishers).

Where required by the provisions of another section of this Code, portable fire extinguishers shall be installed, inspected, and maintained in accordance with NFPA10, Standard for Portable Fire Extinguishers. NFPA 101 9.7.4.1*

Fire Extinguisher
The employer shall provide portable fire extinguishers and shall mount, locate and identify them so that they are readily accessible to employees without subjecting the employees to possible injury. OSHA 1910.157(c)(1)

BLOCKED
Where required by the provisions of another section of this Code, portable fire extinguishers shall be installed, inspected, and maintained in accordance with NFPA10, Standard for Portable Fire Extinguishers. NFPA 101 9.7.4.1*

Fire Extinguishers Monthly Inspection

Inspect Monthly & Sign-off 1910.157(e)(2) Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly. (1910.157(d)(3) standpipe replacing fire extinguishers).

Where required by the provisions of another section of this Code, portable fire extinguishers shall be installed, inspected, and maintained in accordance with NFPA10, Standard for Portable Fire Extinguishers. NFPA 101 9.7.4.1*
This condition was not simply a one-time occurrence, it was the general overall condition.

Eye Washes
Attach tags, inspect & signoff monthly

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. OSHA 1910.151(c)

Limited/Blocked Access to Disconnect Means

Disconnect means & electrical panel boxes must be accessible to employees in cases of emergency shut-down & lockout/tag out procedures. During our assessment it was observed as a general condition where material was stored/stacked in front and in close proximity of disconnect means. In bakery area there were several electrical boxes where yellow painted floor marked the zone of not storage and this was generally observed. In one case the disconnect means was in the off position with no tag (no apparent LOTO procedure). This is displayed in the first slide following. In & of itself this is not a violation however, it does communicate misinformation as to the status of the machine/equipment or device it supplies. It is advisable to communicate with tags the status of disconnect means or electrical equipment in repair or out-ofservice.

Limited/Blocked Access to Disconnect Means Switch in off-position

without a locksends mixed message to employees including the disposition of the switch & machine/device/ operation associated with it. 1910.147(c)(7)(i) The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees.

Limited/Blocked Access to Disconnect Means

1910.305(j)(4)(v) The disconnecting means shall be readily accessible. If more than one disconnect is provided for the same equipment, only one need be readily accessible.

BLOCKED

Limited/Blocked Access to Disconnect Means Zoom Angle

Shells
This raised disconnect makes it impossible for employees to shut-down its associated machine/equipment/device without the aid of a ladder.

BLOCKED

Limited/Blocked Access to Disconnect Means

Dock Area

BLOCKED

Limited/Blocked Access to Disconnect Means

Various Locations

BLOCKED

Limited/Blocked Access to Disconnect Means

BLOCKED Various Locations

Limited/Blocked Access to Disconnect Means

BLOCKED
Various Locations

Limited/Blocked Access to Disconnect Means

BLOCKED Various Locations

Walking Working Surfaces & Housekeeping

Generally the walking working surfaces including housekeeping were acceptable for the type of operation at XYZs Foods. There were only a few issues under this standard in the following slides. Most areas were clean & dry. 7.1.8 Elements of the means of egress that might require protection with guards include stairs, landings, escalators, moving walks, balconies, corridors, passageways, floor or roof openings, ramps, aisles, porches, and mezzanines. NFPA 101

7.5.1.1.1 Where exits are not immediately accessible from an open floor area, continuous passageways, aisles, or corridors leading directly to every exit shall be maintained and shall be arranged to provide access for each occupant to not less than two exits by separate ways of travel, unless otherwise provided in 7.5.1.1.3 and 7.5.1.1.4. NFPA 101

Walking Working Surfaces

A.7.1.8 Elements of the means of egress that might require protection with guards include stairs, landings, escalators, moving walks, balconies, corridors, passageways, floor or roof openings, ramps, aisles, porches, and mezzanines. NFPA Life Code 101-2009 Aisle Accessway. The initial portion of an exit access that leads to an aisle. NFPA 101 3.3.11* Add handrails to this side descending to ensure ease of transition. 1910.23(d)(1) Every flight of stairs having four or more risers shall be equipped with standard stair railings or standard handrails as specified in paragraphs (d)(1)(i) through (v) of this section, the width of the stair to be measured clear of all obstructions

Electrical Hazards
The areas of concern for the electrical hazards are: Strain relief issues where colored wire is exposed and present a potential shock or electrocution Minimal observation of knock-outs missing One issue of live receptacles/light fixtures were observed Electrical panel access was limited (addressed in disconnect means). Need for an Arc Flash Analysis
The overall issue of electrical hazards were minimal at XYZs Foods. These issues will need to be addressed as quickly as possible.

Electrical Hazards
Various Locations
Fittings. Connectors used to connect lengths of cable in a run shall be of a type that lock firmly together. Provisions shall be made to prevent opening or closing these connectors while energized. Strain relief shall be provided at connections and terminations. OSHA 1910.305(h)(6) Acceptable spool: Allneed to ensure strain relief at connection point

Unacceptable transition (no spool) from source

Electrical Knockouts
Repair with Approved Parts Tighten Bushing
Fittings. Connectors used to connect lengths of cable in a run shall be of a type that lock firmly together. Provisions shall be made to prevent opening or closing these connectors while energized. Strain relief shall be provided at connections and terminations. OSHA 1910.305(h)(6)

Listed (approved parts) for repair Unused openings protected. NEC 2008 Article 110.3(B) Listed (approved parts) for NEC 2008 Article 110.12(A) repairs OSHA 1910.303(b)(2)

Electrical Hazards
XYZs Area
Repair with Approved Parts Listed (approved parts) for repair NEC 2008 Article 110.3(B) Unused openings protected. NEC 2008 Article 110.12(A) Listed (approved parts) for repairs OSHA 1910.303(b)(2)

Electrical Hazards
Repair with Approved Parts

Listed (approved parts) for repair NEC 2008 Article 110.3(B) Unused openings protected. NEC 2008 Article 110.12(A) Listed (approved parts) for repairs OSHA 1910.303(b)(2)

Electrical Hazards
Care should be taken as not to use flexible cords (extension cords) as permanent wiring.

Flexible cords and cables shall be approved for conditions of use and location. OSHA 1910.305(g)(1)(i)

Electrical Hazards

Avoid pinch points for electrical cords

Electrical Hazards
Consider an Arc Flash Analysis for the entire facility

Arc Flash Analysis needs to include the user (or at the box) warning signs that identify the flash hazard level and required PPE installed on every electrical panel.

Hoist Safety
Hoist must be treated as cranes for use, inspection, maintenance, and care. To do less begs accidents. The major issues for the hoists are: Lack of disconnect readily accessible & labeled as such Pendent electrical cables wrapped around hoist hook Documentation for frequent and periodic inspection (must be compiled & available) Annual inspection of the hoist by a qualified (or third party) inspector & documented Hoist capacity not clearly visible from the floor Suspended load unattended is a serious violation This hoist issue is another opportunity for systematic correction. The event of an incident with a hoist is significant due to the load configuration and frequency of use.

Hoist Disconnect
Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe. OSHA 1910.147(d)(5)(i) At the beginning of each operator's shift, the upper limit switch of each hoist shall be tried out under no load. Extreme care shall be exercised; the block shall be "inched" into the limit or run in at slow speed. If the switch does not operate properly, the appointed person shall be immediately notified. 1910.179(n)(4)(i)

Locate a Disconnect Means

Ensure Periodic & Frequent Inspections The employer shall insure that the operator (Document) does not leave his position at the controls while the load is suspended. 1910.179(n)(3)(x)

Hoist Safety
Electrical pendent cord running through the hook. This practice could cause the electrical cord to be damaged and cause a shock or electrocution if adverse conditions are present.

Forklift Safety

Forklift Safety
1910.178(a)(5) If the truck is equipped with front-end attachments other than factory installed attachments, the user shall request that the truck be marked to identify the attachments and show the approximate weight of the truck and attachment combination at maximum elevation with load laterally centered. Note: it is very important to ensure positive connection when using a personnel working platform

Permit-Required Confined Space

Permit-Required Confined Space (PRCS) requires: A written program Space assessment Space labeling Training for entry including emergency rescue & recovery

Hazardous Material
Caps should be replace on stored cylinders. This is more predominant in construction 1926 rather than 1910 general industry. It is simply a good practice.

Rotating Shafts
Projecting shaft ends. 1910.219(c)(4) Projecting shaft ends shall present a smooth edge and end and shall not project more than one-half the diameter of the shaft unless guarded by nonrotating caps or safety sleeves. 1910.219(c)(4)(i)

Cover or cut-off shaft ends

Rotating shaft protrusion hazard

Rotating Shafts

Rotating shaft protrusion hazard

Cover or cut-off

Ergonomics
Although OSHA does not have a specific standard that horizontally addressed ergonomics every citation is accompanied with a letter that specifically and clearly identifies ergonomics as a significant safety factor. The OSHA suggestion for ergonomics is based on systematic change throughout your plant. Some suggestions are: Using mechanical devices where possible such as hoist, lift tables, caddies, & roll carts Using rotation Performing stretching exercises Health programs that emphasize health lifestyles

Flour is classified as a combustible dust and requires potential critical incident management Ammonia is classified as a hazardous substance and as such must be managed with the Process Management System under 1910.119 Purpose. This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards. 1910.119 Process Management Systems Combustible Dust Publication Date: 03/09/2010 Publication Type: Meeting Fed Register #: 75:10739-10740 Standard Number: 1910 Title: Combustible Dust [Federal Register: March 9, 2010 (Volume 75, Number 45)] [Proposed Rules] [Page 10739-10740] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr09mr10-24]. Ammonia Refrigerant Mechanical Refrigeration and Air-Conditioning Installations Aboard Ship. ANSI/ASHRAE 26-1996, (1996). Provides the minimum general requirements for the design, construction, installation, operation, inspection, and maintenance of mechanical refrigeration and air-conditioning equipment aboard ships to permit the safe, efficient, and reliable operation of such systems.

Combustible Dust/Process Safety Management

Recommendation
Overall your plant is in fairly good condition. The food industry typically have tremendous housekeeping hazards. Areas that need addressed are listed below and are listed in the order of typical increased violation dollars of fines: Hazard Communication Emergency Action Plan/Exits/Egress Fire Safety/Eye Washes Limited/Blocked Access to Disconnect Means Walking/Working Surfaces/Housekeeping Electrical Hazards Hoist Safety Forklift Safety (PIT) Permit-Required Confined Space Ergonomics General Programs/Documentation

General Programs/Documentation/ Recommendation

Each of the headings were addressed as if an OSHA inspection was conducting an inspection. Hazard communication is the most often cited issue, followed by exit/egress, then fire safety. It is noteworthy to clarify that housekeeping is the first view an inspector sees in the plant, however, this is after the initial review of documentation including all programs. The focus of an OSHA inspection is dictated by the reason of the visit but Compliance Officers will certainly look at the programs first. Once the programs, and of course, the recordkeeping is reviewed their motivation is to discover the obvious and to look deeper into the disconnects. Disconnect here is defined as the gaps between the written program, the practices and what the Compliance Officer observes. Alignment is key. Align your written programs to your practices, and your employees behavior. Your most difficult task is to discover these gaps.