It’s not exactly hard to tell the difference between an office and an oil refinery. For OSHA, the idea is no different. After completing 36,163 federal inspections and 47,217 more done by state plans in FY 2014, the agency has announced a new protocol for inspections that will allow it to give added weight to the most demanding and complex inspections.
The Enforcement Unit and Enforcement Weighting
Announced on a DOL blog and at the National Safety Council Conference on October 1, 2015 by Dr. David Michaels, Assistant Secretary of Labor for Occupational Health and Safety, OSHA will be implementing a new inspection protocol based on a new unit of measurement: The Enforcement Unit.
The Enforcement Unit (EU) was created so that inspectors do not shortchange difficult inspections. Weighted on a nine-point scale, routine inspections only expected to take a few hours are valued as one Enforcement Unit, while inspections that take longer and are more complex could receive up to eight units.
“All inspections aren’t equal ‒ some are complex and require more time and resources ‒ and many of those inspections have the greatest impact,” Michaels said. “This new system will help us better focus our resources on more meaningful inspections.”
While emphasizing that this in no way will constitute a quota, the change will allow enforcement personnel to take on complicated inspections without worrying about whether they are meeting goals for individual inspections.
Examples of different weightings include the following:
- Process Safety Management (PSM) inspections = 7 units
- Workplace violence inspections = 3 units
- Inspections involving a chemical for which there is no permissible exposure limit = 3 units
A Change Two Years in the Making
After two years of analysis calculated by national and local OSHA personnel, the final plan released on October 1 was one that has been tested throughout FY14, with the EU count totaling 44,439.
“For two years, we piloted the weighted approach, running it side-by-side with our traditional inspection counting system. And we found that tracking inspections by complexity ensures that we don’t shortchange the more difficult inspections in favor of those that can be done quickly. We will continue to monitor this new approach and make adjustments as needed.”
For FY 2015, the intent was to increase EU count by 5,036 to reach 49,475, with FY 2016 expected to increase by another 3,000.
What This Means for Employers
With less perceived pressure to complete individual inspections and a better plan throughout the year, complex inspections will be more thorough.
For employers that are working hard to protect employees using an effective safety management system, your inspection will go smoothly with no citations. However, if your safety system is lax, your processes are flawed, or there are any unsafe behaviors, OSHA will find, cite, and sometimes even shame you.
Related: OSHA Taking a Journalistic Approach to News Releases
Having an effective safety management system is the best way to ensure the returns on engagement, productivity, and profitability—your Return on Safety.
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