Internal audits are a fact of life for many environment, health and safety professionals -- especially those working for large companies. I recently had a discussion with a long-time Phylmar client about internal safety audits. There is a lot of guidance and advice available on how to prepare for such audits and how to create corrective action plans to respond to audit findings.
Recently, I did some health and safety “due diligence” consulting work for a client who wanted to acquire a small, 65-employee business. I thoroughly enjoyed meeting with supervisors and employees and touring the facility and was struck by two important findings: this small company didn’t have much by way of written programs that supported health and safety regulatory compliance AND it had a remarkably good safety record -- one that much larger companies would envy.
OSHA’s regs and enforcement have framed health and safety work for decades. If OSHA reduces its regulatory activity (delaying or reversing current regulations) and moves toward technical assistance, what might the impact be?
On April 20, 2015, the U.S. Equal Employment Opportunity Commission (EEOC) published a Notice of Proposed Rulemaking (NPRM) describing how Title I of the Americans with Disabilities Act (ADA) applies to employer wellness programs that are part of group health plans. The NPRM is available in the Public Inspection portion of the Federal Register.
Consider this scenario: Your firm has just completed a project that involved assessing your client’s status with regard to OSHA’s Voluntary Protection Program (VPP) and making recommendations to close its gaps.