In August, OSHA compliance officers in six field offices - Harrisburg, Pa.; Austin, Tex.; Billings, Mont.; Cincinnati, Ohio; and Atlanta East and West - began conducting general industry inspections using the Program Evaluation Profile (PEP) Form OSHA-195 in a pilot study that runs until November 15. The safety ratings derived from the evaluation will be factored into a new formula for adjusting penalties, also to be given a tryout.

For years, inspectors have less formally assessed safety and health programs based on OSHA's 1989 voluntary management guidelines, and used those evaluations to determine "good faith" discounts in penalty cases. The new audit system, with its 15 itemized program subsets and accompanying tables that broadly define five performance grades for each component, take OSHA's evaluation process to a more sophisticated level.

It also gives safety and health professionals an opportunity as never before to look at their programs from OSHA's perspective. It's easy enough to get the detailed documents agency inspectors will be using: You can download the PEP form from OSHA's Internet site at by clicking first "Other OSHA Documents," then "Directives," followed by "Information Date" and "1996 Directives Table of Contents." Or you can send a self-addressed label to the U.S. Department of Labor, OSHA/OSHA Publications, PO Box 37535, Washington, DC 20013-7535; (202) 219-4667.

Beginning next month, Industrial Safety & Hygiene News will begin a series to help you conduct a self-audit using OSHA's specific criteria. Here's how we'll cover each of the 15 components:

  • October (management leadership, employee participation, implementation, contractor safety);
  • November (survey and hazard analysis, inspection, hazard reporting, accident investigation, data analysis);
  • December (hazard control, maintenance, medical programs, emergency preparedness, first aid);
  • January (training, and finalizing the evaluation process).

During PEP's trial run, OSHA inspectors will rate each of these program components on a scale of 1 (absent or ineffective) to 5 (outstanding), helped by 15 tables listing descriptors of workplace characteristics that best fit what they see in the field. Using these categories and ratings tables, you can do the same thing in your own facility.

This is how it works: Six core elements - management leadership and employee participation, workplace analysis, accident and record analysis, hazard prevention and control, emergency response, and training - are divided into the 15 components, or what OSHA calls factors. Each factor receives its own rating, and the score for each of the six elements is determined by the average of the element's factor scores.

Two exceptions: The score for the management leadership and employee participation element (which OSHA considers the foundation of a program) will be based on whichever is the lowest of the following: the score for management leadership; the score for employee participation; or the average score for all four factors. The sixth element, training, has no separate factors and so receives just one score.

The overall score for a work site will be the average of the six scores for core elements (see scorecard below), rounded to the nearest whole number.

If an element or factor does not apply to a work site, it will be noted as "not applicable" and will not affect the score.

Getting started

Safety and health consultant Ray Colvin of Safety Training Dynamics in The Woodlands, Tex., offers these tips for working with OSHA's PEP form:
  • Start with getting management's support and involvement in this quantitative review. Make sure managers understand that as part of their approval, they will have to follow up and address all issues that might be uncovered.
  • Emphasize that OSHA is currently testing this audit process - it is not a standard or even a nationwide policy at this point. Plus, the audit addresses areas that are not covered by specific OSHA requirements, such as management leadership and employee participation. Managers also should know that audit results constitute a legal paper trail of their "problems."
  • Make a presentation to senior facility staff outlining the audit steps and their involvement in the process. Ideally, senior staffers would become part of the audit team that goes out to collect the data needed - or at least they support the team's work.
  • Work through safety committees to organize a game plan for implementing the OSHA self-audit. Then see how your performance rates.