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Part 1
Draft a letter in response to the complaint. Your letter should summarize why you believe the complaint is invalid and no on-site inspection is required. Keep in mind, simply stating that the complaint is invalid is not adequate. You must support your opinions in the letter.
Part 2
Where does this type of complaint fit on OSHA’s priority criteria?
What factors could have made this complaint non-formal rather than formal?
1) Under what conditions can an employee be denied access to the opening conference, walk-around, and closing conference?
Your response should be at least 75 words in length.
2) Can an employee request that an attorney or union representative attend a private conference with the compliance officer? If the union demands to have a representative present, does the employee have to comply?
Your response should be at least 75 words in length.
3) If OSHA determines that an employer’s response to a non-formal complaint is adequate, what options does the employee filing the non-formal complaint have?
Your response should be at least 75 words in length.
4) If the OSHA compliance officer requests documents that are not related to a formal complaint, what options do you believe the employer has?
Unit I Assignment Slide 3 Voicemail Transcript
Hi Jerry! This is your OSHA’s Area Director.
We received a non-formal complaint recently from one of your current employees. The complaint alleges
that employees there are performing welding operations on stainless steel in an area with inadequate
ventilation.
This employee also states that they frequently “cough up” black sputum, and that they are worried about
the health consequences caused by this lack of ventilation.
The complaint further states that no air sampling has been performed to evaluate the employees’
exposures to welding fumes. And, that when asked for respirators, they were given “dust masks” with one
strap, which were purchased at the local hardware store. The effectiveness of these dust masks for the
exposure that is present is also in question.
I will also be sending you an email summarizing this non-formal complaint, so that you can respond
accordingly.
Thanks Jerry! Goodbye.
UNIT II STUDY GUIDE
OSHA’s Inspection Process
Course Learning Outcomes for Unit II
Upon completion of this unit, students should be able to:
2. Evaluate occupational safety and health regulations and laws.
2.1 Describe appropriate steps to take during a walk-through to reduce citations and penalties.
2.2 Discuss the employer’s rights during an on-site inspection.
4. Assess employee rights related to workplace safety.
4.1 Describe the options an employee has when filing a non-formal complaint.
4.2 Describe the employee’s rights to be represented and participate in an on-site inspection.
Course/Unit
Learning Outcomes
2.1
2.2
4.1
4.2
Learning Activity
Required Reading, Assignment
Required Reading, Assessment
Required Reading, Assessment
Required Reading, Assessment
Reading Assignment
OSHA’s Field Operations Manual (FOM): Click here to access a PDF document of the FOM.
Chapter 3: Inspection Procedures
Chapter 9: Complaint and Referral Processing, pp. 9-6 through 9-7
In order to access the following resource, click the link below:
Occupational Safety and Health Administration. (2016). Field operations manual. Retrieved from
https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-160.pdf
Unit Lesson
As stated in Unit I, the primary purpose of the Occupational Safety and Health Administration (OSHA) is to
protect workers. One tool that OSHA uses is to conduct inspections of workplaces based on the priority
criteria that we also discussed in Unit I. Prioritizing inspections allows OSHA to make the best use of the
resources that are available.
Congress has placed some restrictions on OSHA’s ability to conduct inspections through the annual
appropriation bills. Historically, the limitations on inspection have been for small farming operations and small
employers in low-risk industries (OSHA, 2016). For example, OSHA is not allowed to conduct any inspection
of a farming operation if the farm has had 10 or fewer employees and has not had an active temporary labor
camp during the preceding 12-month period. Small businesses in low-risk industries are only exempt from
programmed inspections, but there are limitations on the citations and penalties that OSHA can issue when
an inspection is performed related to an employee complaint (OSHA, 1998).
Another area where OSHA’s ability to inspect a workplace is limited is when another federal agency has
regulatory oversight. Examples include sites regulated by alcohol, tobacco, and firearms (ATF), the
Department of Energy (DOE), the Environmental Protection Agency (EPA), the Federal Aviation
Administration (FAA), the Mine Safety and Health Administration (MSHA), and the Nuclear Regulatory
BOS 3525, Legal Aspects of Safety and Health
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Commission (NRC). In many cases, OSHA has reached an agreement with the
other
regulatory
agencies
UNIT
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concerning each agency’s responsibilities. These agreements are called memorandums
of understanding
Title
(MOUs). You can read some of the current MOUs by clicking the following link:
https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=MOU&p_toc_level=1&p_keyvalue=Ag
ency&p_status=CURRENT
In general, OSHA is not allowed to provide advance warning of on-site inspections. 29 CFR 1903.6, provides
exceptions to the prohibition of advance warning of inspections, including when situations of apparent
imminent danger are present (OSHA, n.d.-b). The advance warning, in this case, is permitted to give the
inspection site the ability to abate the danger as soon as possible. Advance notice can also be given if an
inspection can be more effective if it is conducted outside of normal business hours. If specific representatives
of the company are required to be present for an inspection, then advance warning is also allowed. For
example, suppose a safety and health officer must travel from corporate headquarters for the inspection.
Finally, the area director may decide that providing advance notice of an inspection will help to obtain a more
effective and thorough inspection.
As mentioned in Unit I, OSHA’s authority to conduct on-site inspections and owners’ rights under the Fourth
Amendment to the U.S. Constitution were tested after the OSH Act was passed. The Fourth Amendment to
the U.S. Constitution prohibits unreasonable searches and seizures and requires any warrant to be supported
by probable cause and to be signed by a judge (U.S. Const. amend. IV). Section 8(a) of the Occupational
Safety and Health (OSH) Act authorizes OSHA to enter any facility covered under the act without delay and at
reasonable times to inspect and investigate the property, including questioning the employer, owner, operator,
agent, or employees privately. Since these two documents appear to conflict with each other, it was inevitable
that the warrantless inspection would be challenged in court. The challenge eventually was heard by the U.S.
Supreme Court in 1978 in the case Marshall v. Barlow’s, Inc. (1978).
The Supreme Court ruled that warrantless inspections by OSHA did violate the Fourth Amendment, and
OSHA was required to obtain a warrant unless consent was given by the owner. In order to allow for the
effective conduct of inspections as required by Section 8(a), OSHA amended 29 CFR 1903.4. The
amendment allows OSHA to obtain warrants under an ex parte basis, meaning OSHA can, under some
circumstances, obtain a warrant in advance of an inspection without the knowledge of the owner (OSH,
1970). This allows OSHA to perform inspections of facilities without advance notice if the area director
determines advance notice would be detrimental to the inspection process. This may include knowledge that
a specific employer will not allow a warrantless inspection, the facility is located a great distance from the
OSHA office so a refusal for entry would require significant time and effort to obtain a warrant, or in instances
where special equipment or experts are required for the inspection.
OSHA inspections can be programmed or un-programmed. Programmed inspections are aimed at facilities
with the highest rates of injuries and illnesses through OSHA’s Site-Specific Targeting (SST) program. These
inspections are designed to improve the health and safety of workers at locations with high injury and illness
rates based on data collected through the OSHA Data Initiative (ODI). However, you can also have programrelated inspections. These inspections are when another employer at a multi-employer is included in the
inspection, even though they were not the employer with the high injury and illness rate.
Unprogrammed inspections are those inspections performed in response to the imminent dangers,
fatalities/catastrophes, complaints, and referrals we read about in Unit I and follow-up inspections performed
after initial inspections. You can also have inspections that are not related to the program. These inspections
are when another employer at a multi-employer is included in the inspection, even though they were not in the
original complaint.
OSHA may perform two types of inspections for programmed or unprogrammed inspections: comprehensive
or partial. As the name implies, a comprehensive inspection is an inspection that covers all potentially
hazardous areas of a site very thoroughly. A partial inspection focuses on specific hazardous operations,
areas, conditions, or practices at a facility. A partial inspection may be changed to a comprehensive
inspection during the inspection at the discretion of the compliance officer.
BOS 3525, Legal Aspects of Safety and Health
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The majority of inspections are performed during
operating
UNIT xnormal
STUDY
GUIDE hours.
The hours of the inspection can be changedTitle
if warranted. For example, if a
complaint is determined to relate to an activity that is only performed during
the third shift at a facility, the inspection would most likely be performed
during that shift.
The majority of inspections follow the same basic format: presentation of
credentials, entry, opening conference, review of records, walk-around
inspection, and closing conference.
OSHA compliance officers will always present their credentials when they
arrive at a facility. This allows the employer to verify that the individual
performing the inspection is, in fact, an OSHA compliance officer. It is at
this point in the inspection that the employer will either allow the
compliance officer to enter the facility to perform the inspection or refuse
entry and require the compliance officer to obtain a warrant. If an employer
refuses entry to an OSHA compliance officer, the compliance officer will try
to obtain as much information as possible and then notify the area director.
Pictured is a compliance officer
The area director then will take steps to obtain a warrant if OSHA decides
conducting an inspection.
to continue the inspection. If the workplace is a multi-employer work site,
(Slavin, 2011)
permission to enter and conduct the inspection can be obtained from any of
the employers at the workplace. At this time, the compliance officer informs the employer’s representative that
employees will be allowed to have a representative participate in the inspection process.
After being allowed to enter a work site, the OSHA compliance officer will conduct an opening conference.
During this conference, the employer will be told about the reason for the inspection. A copy of any complaint
will be provided to the employer. The opening conference is usually very short so the compliance officer can
start the site walk-around as soon as possible. In some cases, the compliance officer will conduct a very brief
opening conference. This may occur if there is evidence that an imminent danger is present and the
compliance officer wants to conduct the walk-around as soon as possible. The opening conference may
include one or more employee representatives if the employer does not object. If the employer objects to the
employee representative(s) being present at the conference, the compliance officer will hold a separate
opening conference with the employee representative(s). The compliance officer may request certain
documents during the opening conference, including a list of chemicals on the site, injury and illness records,
and required written programs and training records. The field operations manual specifically states that the
compliance officer will ask for a copy of the written hazard assessment required by 29 CFR 1910.132(d) and
the injury and illness records for three prior years.
The compliance officer will perform a walk-around inspection of the facility after the opening conference is
completed. Both employer and employee representative(s) may accompany the compliance officer on the
walk-around inspection. The compliance officer may decide if a specific representative is allowed to
participate in the walk-around inspection. The primary purpose of the walk-around inspection is to identify
potential health and safety hazards. The compliance officer is required to bring to the attention of the
employer and employee representatives any health and safety violation that is discovered during the
inspection.
Based on the information OSHA has prior to the inspection and the information obtained during the walkaround inspection, the compliance officer may decide to collect air and/or surface samples at the facility.
Once analytical results have been received, a summary of the results must be provided to employees who
were exposed or are likely to be exposed to the hazard, the employer representative(s), and the employee
representative(s).
The compliance officer may also choose to interview a certain number of nonmanagerial employees in private
during the inspection. The compliance officer is authorized to interview any employee privately and can
choose the employees to interview without intervention from management. The interviews can be used to
determine if the employer received advance notice of the inspection and altered the practices at the site to
prevent the compliance officer from observing normal practices, to determine what safety practices are
typically in place at the site, and to obtain any additional information the compliance officer may deem
appropriate. Employees who are chosen for the interviews may ask for a representative to be present,
BOS 3525, Legal Aspects of Safety and Health
3
including a representative from their labor union. Statements that are made during
interviews
will remain
UNITthe
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confidential unless the employee specifies otherwise.
Title
A closing conference will be conducted at the end of the inspection. The closing conference can be held onsite or delayed and held by telephone conference call at the compliance officer’s discretion. Apparent
violations and other information about findings from the inspection will be presented at the closing conference.
The employer is provided with a copy of an OSHA document that informs them of their rights related to
citations and penalties. If applicable, the compliance officer can also discuss potential control methods that
the employer can implement related to the safety and health hazards identified during the inspection.
References
Marshall v. Barlow’s, Inc., 463 U.S. 307 (1978).
Occupational Safety and Health Act, 29 U.S.C. § 651 (1970).
Occupational Safety and Health Administration. (1998). Enforcement exemptions and limitations under the
Appropriations Act. CPL 02-00-051. Retrieved from
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1519
Occupational Safety and Health Administration. (2016). Field operations manual. Retrieved from
https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-160.pdf
Slavin, G. (2011, February 8). US Department of Labor [Image]. Retrieved from https://flic.kr/p/abPfZP
U.S. Const. amend. IV
U.S. Department of Labor. (n.d.-a). Objection to inspection, 29 CFR § 1903.4. Retrieved from
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9608
U.S. Department of Labor. (n.d.-b). Advanced notice of inspections, 29 CFR § 1903.6. Retrieved from
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9610
Suggested Reading
In order to access the following resources, click the links below:
If you are interested in learning more about the OSHA inspection process, review the resources below.
Occupational Safety and Health Administration. (n.d.). Injury and illness: Recordkeeping. Retrieved from
https://www.osha.gov/recordkeeping/odi-background.html
Occupational Safety and Health Administration. (n.d.). Inspection summary. Retrieved from
https://www.osha.gov/dep/2013_enforcement_summary.html
Occupational Safety and Health Administration. (n.d.). OSHA fact sheet: OSHA inspections. Retrieved from
https://www.osha.gov/OshDoc/data_General_Facts/factsheet-inspections.pdf
BOS 3525, Legal Aspects of Safety and Health
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Learning Activities (Nongraded)
UNIT x STUDY GUIDE
Title
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Twenty-six (26) states, Puerto Rico, and the U.S. Virgin Islands have OSHA-approved state OSHA programs.
These state programs can be more stringent in inspection priorities, citations, and penalties. Access the
OSHA website below:
https://www.osha.gov/dcsp/osp/index.html
Review some of the state plans. See if you can determine which states have more stringent enforcement
programs than federal OSHA.
BOS 3525, Legal Aspects of Safety and Health
5
UNIT I STUDY GUIDE
OSHA’s Inspection Priorities
Course Learning Outcomes for Unit I
Upon completion of this unit, students should be able to:
1. Assess Occupational Safety and Health Administration (OSHA) rulemaking, enforcement, and
adjudication processes.
1.1 Assess OSHA’s priority list for performing on-site inspections.
1.2 Discuss OSHA’s response to employee complaints.
Course/Unit
Learning Outcomes
1.1
1.2
Learning Activity
Required Reading, Assignment
Required Reading, Assignment
Reading Assignment
OSHA’s Field Operations Manual (FOM): Click here to access a PDF document of the FOM.
Chapter 1: Introduction
Chapter 2: Program Planning
Chapter 9: Complaint and Referral Processing
In order to access the following resource, click the link below:
Occupational Safety and Health Administration. (2016). Field operations manual. Retrieved from
https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-160.pdf
Unit Lesson
The path to health and safety laws protecting the American worker has
taken a long and tenuous track. The process did not start until after the Civil
War when industrial operations increased and young, inexperienced
workers were placed in situations where they were using chemicals and
machines for which they had inadequate training (MacLaury, 1981).
Prior to 1970, occupational safety and health regulations were primarily
promulgated at the state level. The process resulted in uneven laws and
enforcement efforts to protect workers. The first state law regarding health
and safety was passed by Massachusetts in 1877 (MacLaury, 1981). That
particular regulation required machine guarding and adequate fire exits.
Other states passed similar inspection laws in the ensuing years; however,
very few states passed regulations related to the health of employees.
Pictured is an Occupational Safety
and Health (OSH) logo.
The first permanent federal bureau to specifically address worker health and
safety was the Bureau of Labor Statistics in 1934 (MacLaury, 1981). In
(Mollohan, 2011)
1960, the U.S. Department of Labor issued a set of mandatory safety and
health rules. These rules were not received well by industries where legal action was taken to prevent their
implementation. President Lyndon Johnson attempted to pass a health and safety regulation in 1968 based
on the rules published by the U.S. Department of Labor in 1960, but the proposed legislation was defeated in
BOS 3525, Legal Aspects of Safety and Health
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Congress (MacLaury, 1981). However, the federal government adopted someUNIT
healthx and
safety
regulations in
STUDY
GUIDE
the 1960s, which offered protection for workers in certain industries. For example,
Titlethe McNamara-O’Hara
Service Contract Act of 1965 and the Federal Construction Safety and Health Act of 1969 were passed to
provide some protection for contractors who were providing work for the federal government. The Metal and
Nonmetallic Mine Safety Act of 1966 was authorized to protect coal miners after several tragedies occurred at
mines involving multiple deaths (MacLaury, 1981).
President-elect Richard Nixon proposed his own version of a safety and health bill after he won the election
and prior to taking office. One difference between President Nixon’s proposed legislation and President
Johnson’s legislation was that Nixon’s bill established that a five-person board would be responsible for
setting and enforcing laws. Responsibilities for worker safety and health would be split between the U.S.
Department of Labor, which would handle inspections, and the Department of Health, Education, and Welfare
(HEW), which would be responsible for safety and health research (MacLaury, 1981).
Many of the sections of the proposed legislation were opposed by labor groups and supported by business.
Earlier in 1969, Democrats in Congress proposed different bills for health and safety that were similar to the
proposed legislation from President Johnson (MacLaury, 1981). The two Democratic-backed (and laborbacked) versions of the bill proposed by President Nixon were considered after the election was over. The
result was that the Senate and House had to consider a compromise bill that incorporated some aspects of all
of the proposed bills. Congress eventually passed the Occupational Safety and Health (OSH) Act in 1970,
which contained more elements of the Democratic-proposed legislation than the legislation proposed by the
Nixon administration.
The final act included a statement by Congress, which stated that the purpose of the legislation was based
upon the finding “that personal injuries and illnesses arising out of work situations impose a substantial
burden upon, and are a hindrance to interstate commerce in terms of lost production, wage loss, medical
expenses, and disability compensation payments” (OSH Act, 1970, para. 1).
The Occupational Safety and Health Administration (OSHA) was formed in response to the passage of the
OSH Act of 1970. OSHA’s primary purpose is to make sure workers in the United States have safe and
healthy workplaces. This purpose is reflected in the General Duty Clause included in the OSH Act of 1970.
The General Duty Clause includes the following information:
(a) Each employer—
(1) shall furnish to each of his employees employment and a place of employment which are free
from recognized hazards that are causing or are likely to cause death or serious physical harm to
his employees;
(2) shall comply with occupational safety and health standards promulgated under this Act.
(b) Each employee shall comply with occupational safety and health standards and all rules,
regulations, and orders issued pursuant to this Act which are applicable to his own actions and
conduct. (OSH Act, 1970, Duties section)
In order to accomplish that goal, OSHA has been given the authority to pass regulations related to workplace
safety and to enforce those regulations. OSHA also has the authority to inspect workplaces covered by the
OSH Act to identify unsafe conditions and issue citations and fines when unsafe conditions are present. The
right of OSHA compliance officers to enter a facility to inspect and the employer’s rights were contested in
court; the courts ruled that the employer has a right to require OSHA compliance officers to obtain a warrant
prior to allowing an inspection. In some cases, this has resulted in OSHA compliance officers obtaining a
warrant prior to showing up at a facility if they have evidence that the employer might refuse entry.
OSHA regulatory oversight covers about 7 million workplaces. OSHA and the approved state programs do not
have enough compliance officers to inspect every workplace in the United States on a regular basis.
Therefore, OSHA established a priority system to ensure that it manages its resources properly and still
provides adequate oversight of workplaces covered under the OSH Act. OSHA established four inspection
priorities: imminent danger, fatality/catastrophe, complaints/referrals, and programmed inspections.
BOS 3525, Legal Aspects of Safety and Health
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An imminent danger refers to a situation that could cause death or some serious
physical
harm.
These types
UNIT
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of situations will receive the highest priority from OSHA, including an immediate
inspection. In some cases,
Title
OSHA can perform immediate actions, such as removing employees from areas where imminent dangers are
present.
The second highest priority for inspections involves fatalities and catastrophes. OSHA changed its policy for
reporting fatalities and catastrophes on January 1, 2015. The old policy required employers to report any
fatality and any event resulting in three or more employees being hospitalized within eight hours of the
occurrence. The new policy requires employers to report any fatality and any work-related inpatient
hospitalization (only one person required), any amputation, or the loss of an eye within eight hours.
Employees have a right under the OSH Act to file complaints with OSHA about what they believe are safety
and health hazards or violations of OSHA regulations. The complaints can be either formal or non-formal.
Formal complaints have to be filed by current employees or a representative of current employees. The
formal complaint has to assert that an imminent danger is present or that there is some violation of an OSHA
regulation that could cause physical or health harm to occur in the workplace. The formal complaint has to be
written, or the form provided by OSHA (OSHA-7) must be completed and signed by at least one current
employee or a representative. The employee’s identity will remain anonymous upon request. The non-formal
complaint does not meet all the requirements of a formal complaint.
Referrals can come from a number of sources, including other federal agencies, like the Environmental
Protection Agency (EPA), state or local agencies, organizations, individuals who are not current employees,
and the media. OSHA considers each referral and prioritizes the referrals based on an evaluation of the
reliability of the source of the referral.
OSHA uses the reporting of recordable injuries and illnesses each year to calculate average injury/illness
rates for industries in the U.S. Industries with high incident rates are identified. Injury and illness rates for
individual workplaces are compared to the national averages for similar industries to identify locations with
high rates. These industries and individual locations are placed on high hazard lists. OSHA will conduct
inspections of these high-hazard industries and individual work places whenever possible through the SiteSpecific Targeting (SST) Program.
OSHA may also inspect sites that are not on the high-hazard list when adequate resources are available.
These inspections are typically performed using a random sampling method. OSHA inspections can also
occur due to a site’s participation in a voluntary protection program (VPP). These special programs will be
discussed in Unit VIII.
The method OSHA uses in response to a complaint from a current employee or representative will depend on
the nature of the complaint. For a non-formal complaint, initially OSHA may notify the employer by telephone,
fax, email, or letter. The employer will be required to respond to the complaint, and OSHA will notify the
complainant of the employer’s response to determine if the issue can be resolved. If the complainant can
show that the employer’s response is false, or provides additional evidence that the complaint has not been
resolved, an on-site inspection is typically performed. Valid formal complaints, especially those submitted on
the OSHA-7 form that are signed, are typically followed up with an on-site inspection.
References
McLaury, J. (1981, March). The job safety law of 1970: Its passage was perilous. Monthly Labor Review, 18–
24. Retrieved from https://www.dol.gov/oasam/programs/history/osha.htm
Mollohan, R. (2011, July 25). US Department of Labor [Image]. Retrieved from https://flic.kr/p/a6YuvL
Occupational Safety and Health Act, 29 U.S.C. § 651 (1970).
BOS 3525, Legal Aspects of Safety and Health
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Suggested Reading
UNIT x STUDY GUIDE
Title
In order to access the following resources, click the links below:
To learn more about OSHA safety violations and the complaint-handling process, review the resources below.
Occupational Safety and Health Administration. (n.d.). Federal OSHA complaint handling process. Retrieved
from https://www.osha.gov/as/opa/worker/handling.html
Occupational Safety and Health Administration. (n.d.). How to file a complaint with OSHA. Retrieved from
https://www.osha.gov/as/opa/worker/complain.html
Occupational Safety and Health Administration. (1996). Notice of alleged safety or health hazards. Retrieved
from https://www.osha.gov/oshforms/osha7.pdf
Occupational Safety and Health Administration. (2011). OSHA fact sheet: Filing whistleblower complaints
under the Sarbanes-Oxley Act. Retrieved from https://www.osha.gov/Publications/osha-factsheetsox-act.pdf
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
OSHA allows the public to search for information about on-site inspections that have been performed. Access
the OSHA search page below, and find an inspection that is interesting to you:
https://www.osha.gov/pls/imis/establishment.html
You might look at inspections that have occurred at facilities similar to where you work. Hint: You can search
by SIC code. From the information provided, determine which type of inspection was performed based on
OSHA’s priority criteria. Did OSHA provide advance notice of the inspection? Which types of violations were
cited? What were the proposed penalties for this inspection? Were any of the violations downgraded? Were
any of the penalties decreased?
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