Issue link: http://palletcentral.uberflip.com/i/1511664
PalletCentral • November-December 2023 39 follow … and it is 270 pages long (https://www.osha. gov/sites/default/fi les/publications/osha2254.pdf )! Before any OHS offi cer departs, this can be used to ensure that the mandated records do exist, establish where they can be located, and then assess whether they are being maintained according to both OSHA rules and the company's internal document retention and destruction program. ere are other elements that make compliance tricky, such as keeping historical records of Safety Data Sheets (SDSs) under OSHA's Hazard Communication Standard for 30 years or more, whenever an SDS is updated. If OSHA does a record audit and seeks to review these documents, lack of succession planning can result in the new safety offi cer having no idea where such documents are stored (hard copy or electronically) or even if the records have been maintained for the mandated period. If a safety offi cer gives two weeks' notice before quitting and leaving the area, the chances of capturing their institutional knowledge and ensuring that any outstanding projects are completed prior to departure are slim to none. Just recently, I handled an OSHA conference over citations that claimed the employer had not done the annual review of an applicable program, and that training had not been provided. While the workers had indeed been trained under the old regime, no documentation could be located. e program at issue was also deemed adequate, but due to transition, no one within the company could identify with any specifi city when it had last been reviewed. e fact that the program bore a 2018 date (in 2023) also captured OSHA's interest. In the end, we were able to cobble together suffi cient information to get the citations vacated, but in the short term they appeared on the company's record, resulting in scrutiny by in-house counsel and the need to retain an outside OSHA lawyer to make the arguments in mitigation. It is not always the case that OSHA will provide the benefi t of a doubt after a long-time safety manager departs without suffi cient succession planning, however. In addition to avoiding confl ict with OSHA and penalties that can reach $156,259 per violation, there are other benefi ts to an employer as a result of including the safety management offi cers in your succession planning. e key value is business continuity – you have someone ready to hit the ground running once the incumbent departs (either anticipated or suddenly). Obviously, fi nancial If a safety offi cer gives two weeks' notice before quitting and leaving the area, the chances of capturing their institutional knowledge and ensuring that any outstanding projects are completed prior to departure are slim to none.