Issue link: http://palletcentral.uberflip.com/i/666889
palletcentral.com PalletCentral • March-April 2016 23 SHMP a requirement in resolving citation/penalty matters at the informal conference level – often including the provision without negotiation – or it can be a negotiated part of a corporate wide settlement agreement in formal contest proceedings. Once agreed to by the employer, the SHMP becomes an enforceable requirement in that employer's workplace(s), and any deficiencies can be considered a failure-to-abate the original citation. This means original penalties could be reinstated, and the failure-to- abate violation can trigger additional penalties and even inclusion in OSHA's Severe Violator Enforcement Program. What do these two initiatives – the LEP and the SHMP – have in common? It is their emphasis on hazard identification and mitigation of any identified conditions that could present a risk of injury or illness to workers. Although the employer may not have committed to implementation of all components of a SHMP, the fact is that thorough hazard assessment is critical to maintaining a safe and healthful workplace and eliminating the exposures that violate OSHA requirements. Without appropriate worksite evaluations, periodic audits, and prompt implementation of corrective action, the employer cannot know what potential sources of harm exist, cannot adequately train workers, and could even face criminal prosecution if a worker is killed on the job and OSHA finds there was "plain indifference" to hazard elimination. The stakes have never been higher: the Department of Labor & Department of Justice recently entered into a Memorandum of Understanding aimed at increasing the volume, and success, of OSHA criminal prosecutions. So how can an employer get started on the hazard identification and abatement effort so that the workplace will be free from problems that could result in horrendous and costly OSHA inspections? First, it is important to understand what is involved. The Local Emphasis Program (LEP) for the Wood Pallet Manufacturing Industr y is CPL 03-00 (LEP-028) and details of the initiative can be downloaded at http://www.osha.gov/dep/leps/leps.html#R5