Risk Management continued from page 16 Many camps have usual and routine practices regarding exposure incidents (when someone’s blood comes in contact with the unprotected skin or mucous membranes of an employee). For example, gloves are commonly found in camp first-aid kits, and staff are expected to use them (right?). We’ve become acclimated to safe behaviors surrounding exposure to the body fluids of others. While great in theory, this OSHA standard still directs that a camp have a written bloodborne pathogens plan and that the camp provide employee training specific to the elements listed in the standard. Now may be a great time for camp professionals to review their standard operating practices to make sure the camp remains in compliance with the standard. Failure to have this written plan is one of the most common reasons to fine a business. Another pertinent OSHA standard is the Hazardous Communication Standard (Haz-Com or Right-to-Know). Like the Bloodborne Pathogens Standard, this one also includes a written plan. The regulation directs that employees be informed about chemicals used in the context of doing their job, instructed in using PPE, familiar with needed first aid should exposure occur, and skilled in reading and/ or referencing material safety data sheets (MSDSs). The chemicals that fall under this standard are those with industry application and household chemicals that are used in greater frequency and/or amount than used by the typical household. This explains why a product such as toilet bowl cleaner — used to clean several camp toilets — is included, but that same chemical, when used in someone’s home with one or two toilets, falls outside the standard. The standard directs that employers collect, organize, and make MSDSs available to employees, that employees are taught how to read both MSDSs and product warning labels, and that employee compliance is monitored. Like other OSHA information, Haz-Com information is available at OSHA’s Web site (www.OSHA.gov). An OSHA Inspection? The most common reason for OSHA to do an inspection within general industries is because a worker (employee) reports an infraction. Employees have the right to contact OSHA (through the state’s Department of Labor) when a rule infraction is suspected. A phone call may be all it takes. While an employee complaint is the most common reason, OSHA inspections can also be triggered by a worker fatality or serious injury. This means that most camp professionals 18 CAMPING magazine • November/December 2013 should have an inkling that such an inspection may occur; one is aware of disgruntled and/or seriously injured employees. The key to a successful inspection is preparation. When the inspector arrives — unannounced — he or she will present identifying credentials and begin with an opening conference. Have a team ready for this conference, specifically the camp director/administrator, someone who will take notes during the inspection, and a person who can be directed to get needed items. Also have materials this team might need, such as a camera (capable of low-light shots), a tape measure, video camera, and clipboard with paper. Finally, automatically bring documents the OSHA team will ask to see. These are typically the 300 log and the written Haz-Com and bloodborne pathogens programs. The reason and scope of the inspection will be disclosed at the opening conference. A walk around follows the opening conference. This is when the OSHA representative will look at selected areas, potentially talk with employees, and will gather data needed to make a determination as to the reason for the inspection. The time allocated to the walk around ranges from very brief to quite long. A closing conference concludes the on-site inspection. The camp’s management will be advised of alleged violations and/or citations, and an abatement date will be set — unless one contests a violation(s). Should a citation(s) be issued, a written copy will eventually arrive via certified mail. Note the date it is received. OSHA directs that citations be posted for three days “near the place where the violation occurred” or until the hazard is corrected. If one believes the citation is unfounded, one can contest by filing a Notice of Contest within fifteen days of receiving the mail-certified citation. An informal conference will typically be arranged with OSHA to discuss the merits of such an appeal. Should merit exist, a hearing date will be set. Most states direct that such arbitration, should it be needed, will be binding. Learning more about a given state’s OSHA inspection process is critical. Perhaps this is the kind of thing that camp professionals can request as a group. Meeting with OSHA may help everyone learn the nuances of the state’s process, obtain clarification about interpretation of specific standards, and obtain consultative knowledge from the proverbial horse’s mouth. Where to Go from Here? This article provides a broad overview of some OSHA components and their application to our camp community. Readers are encouraged to seek further information through their state’s Department of Labor, specifically the state in which the camp is located, and to make use of OSHA’s consultative division. Failure to know about an OSHA directive isn’t an adequate defense. Employers are expected to know about these things. Make sure your camp has updated and revitalized OSHA programs. Linda Ebner Erceg, RN, MS, PHN, is the associate director of Health & Risk Management for Concordia Language Villages and executive director of the Association of Camp Nurses in Bemidji, Minnesota.
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