Title Page

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Section I - OSHA Compliance

Previous Audit Summary

  • A. Have all non-conformances from the EHS audit been completed by due date?

  • Please review open items from previous EHS audit.

  • Have you reviewed open items from previous EHS audit?

Safety Committee/Recognition

  • A. Does the location have a designated safety coordinator?

  • Name of designated safety coordinator.

  • B. Does the location have an established safety committee? If yes, answer the following questions:

  • How many members, management and production?

  • How often do they meet?

  • Does the safety coordinator lead and facilitate the meetings?

  • Are internal safety inspections conducted and documented at least monthly?

  • Do supervisors participate in and document daily safety inspections?

  • C. Does the site have a written incident/near miss investigation procedure?

  • D. Are accident investigations reviewed by the Plant Manager?

  • E. Are root cause analyses conducted and a follow-up system implemented for any recommendations pending?

  • F. Does the facility have a safety suggestion program?

  • G. Does the facility have a formal safety recognition program? (29 CFR 1904.35)

  • H. Does the facility discipline program include actions for safety infractions and is this process documented?

Notice of Act (1903.2)

  • A. Is Notice of Act posted in a conspicuous place or places where notices to associates are customarily posted?

Recordkeeping (1904)

  • A. Are OSHA logs maintained at the site for the previous 5 years, plus the current year? (Note: OSHA 200 logs do not need to be maintained, but must be on file). AUDITOR NOTE: Ask to see all logs and confirm updated and current copy of OSHA Form 300.

  • B. Are one page supplemental reports (i.e. 301 or state FROI's) available for each OSHA 300 log entry?

  • C. Is the certified OSHA Form 300A Summary kept on file for 5 years plus the current year? AUDITOR NOTE: A "certified copy" is a hard copy signed by the highest ranking site official.

  • D. Do questionable entries that have been removed from the OSHA 300 log have written justification for non-recordability?

  • E. If the facility utilizes the services of "Borrowed Servants" (any temporary associate that receives direct supervision from MCC), are these contract associates being logged on the OSHA 300 log?

  • F. Are any incidents identified on the OSHA Form 300 first aid injuries?

  • G. Are work-related recordable injuries/illnesses recorded within 7 calendar days of receiving information that a recordable case occurred?

  • H. Is the previous year's summary of the OSHA log (Form 300A) posted from February 1 to April 30 for the preceding year?

  • I. Is the previous year's summary of the OSHA log signed by the highest ranking company official working at the facility, or the immediate supervisor of the highest ranking company official working at the establishment?

  • J. After reviewing annual hearing records, are all recordable hearing losses recorded as required? Work-related hearing shifts averaging 10 dB or more at 2000, 3000, and 4000 hertz in either ear when compared to the associate's baseline AND the associate has an average hearing threshold level [at 2000, 3000, and 4000 hertz] greater than or equal to 25 dB when compared to audiometric zero.

  • K. Has a procedure been established for associates to report injuries and illnesses and has this procedure been communicated to all associates?

  • L. Does the facility ensure all work related injuries treated by an outside medical facility are submitted to the TPA/Insurance?

  • M. Does the facility have a First Aid log? If yes, has the facility filed FROI’s for work related cases that included services paid to outside medical providers?


  • A. Is new associate EHS training conducted?

  • B. Is annual training completed and documented for all OSHA and EPA standards that affect or this facility is responsible to uphold?

Employee Exposure & Medical Records (1910.1020)

  • A. Does the facility have documentation that associates are informed at the time of employment and annually thereafter?

  • Of their right to access exposure and medical records?

  • Where they are located?

  • The job title responsible for maintaining and providing access to the records?

  • Does the facility have a standard medical record release authorization form?

  • B. Is there a file system to ensure that: (Physically verify file system)

  • Medical records are maintained for at least the duration of employment plus 30 years?

  • Exposure records, including chemical lists or SDS’s, (Industrial Hygiene monitoring, noise surveys, etc.) are maintained for at least 30 years?

  • C. Does the facility have a copy of the standard and appendices available for associates upon request?

  • D. Are associates personally notified of their monitoring results? [Are OSHA substance specific materials, (i.e. lead, asbestos, hex chrome, formaldehyde, etc.) monitoring results provide to associate in writing?]

Hazard Communication and Chemical Management (1910.1200)

  • A. Is a current written Hazard Communication (HazCom) program in place?

  • B. Does the facility have a documented process whereby chemical materials are evaluated for safety / environmental considerations prior to purchasing?

  • C. Is there evidence where associates are made aware of new hazards brought into the workplace? AUDITOR NOTE: see "Chemical Alerts" in Master documents for a method of handling.

  • D. Is an accurate site list of chemical materials available?

  • E. Are Material Safety Data Sheets available for all items on the facility hazardous chemical list? (To verify, check a representative number).

  • F. Are containers of hazardous chemicals labeled, tagged, or marked with a chemical identity and appropriate hazard warning?

  • G. Is there a process to ensure SDSs are available to associates on all shifts?

  • H. Are information and training records available for each associate affected by the HazCom standard? AUDITOR NOTE: Some operations, choose to perform Hazcom standard training annually. Verification of the refresher portion of this question is a random review of refresher training documentation.

  • I. Are all contractors required to submit a list of all chemicals and corresponding SDS’s prior to bringing them on MCC property?

  • J. Has the location conducted a chemical inventory and kept it on file at least annually?

Noise & Hearing (1910.95)

  • A. Has an initial noise survey been completed and kept updated for any major equipment or process changes?

  • B. If needed, is there a written Noise Exposure Program?

  • C. Are all high noise areas posted (continuous 85 dBA and above)?

  • D. Are all associates who are exposed to noise levels above 85 dBA required to wear hearing protection?

  • E. For facilities requiring hearing protection has the hearing protector attenuation been evaluated for specific noise environment in which the protector will be used?

  • F. Are these associates given annual audiometric tests which are compared to their baseline? If associates refuse the test, is a waiver form completed? Check documentation.

  • G. Are new associates receiving audiometric tests? (Within 6 months of hire date or within one year if a mobile test van is used.) Temporary employees follow the same protocol but it can be a shared effort between the agency and the host employer. Any shared responsbility needs to be determined before the temporary associate starts work.

  • H. Are associates advised in writing, within 21 days, of audiometric test or retest results if hearing loss is indicated, or the STS is not persistent?

  • I. Does the facility hearing test provider(s) provide an OSHA recordable hearing loss exception report? NOTE: Is this provider analyzing audiograms to determine potential OSHA recordability?

  • J. Is the Hearing Conservation Standard posted in the facility?

  • K. When audiometric testing is conducted, by outside contractor or at facility, are they meeting the following requirements:

  • Are there records indicating the audiometer has an exhaustive calibration at least every two years?

  • Are the records indicating the audiometer is calibrated at least annually?

  • Is the audiometer checked before each day’s use?

  • Is the person conducting audiometric tests properly certified?

  • Have background noise checks been conducted on hearing booth?

  • L. Is training provided to associates that are exposed to noise levels above 85 dBA TWA?

Personal Protective Equipment (1910.132)

  • A. Has a Personal Protective Equipment (PPE) hazard assessment of the workplace been completed?

  • B. Is there a formal certification that the assessment has been completed?

  • C. Has initial training been conducted and retraining as required for associates to identify the need for PPE, what PPE is necessary, how to use the PPE, the limitations, and proper care, maintenance and disposal of the PPE.

  • D. Does the PPE Training include a written certification that it was performed and understood and does it include the name of each associate trained, date trained, and subject certified?

Respiratory Protection (1910.134)

  • A. Have all chemical requirements and need for respirators been reviewed for this site?

  • B. If respirators are used (required or voluntary), does the site have a written Respiratory Program?

  • C. Are there tasks that require air purifying cartridge respirator or supplied air respirator? If yes:

  • What types of respirators are used in this facility?

  • What tasks require these types of respirators?

  • Have respirator users received medical fitness evaluation and are these evaluations documented? (Note: Medical clearance must be done before fit tests)

  • Are users receiving appropriate (annual) fit tests and are these tests documented?

  • D. Where filtering face piece respirators (dust masks) are used on a voluntary basis, does the facility provide respirator users with information contained in Appendix D of the standard? AUDITOR NOTE: These must be completed annually and copies kept until new forms are completed)

  • E. Have users been instructed and trained in the proper use of the respirator, and is this training documented? (any type of respirator including dust mask and required or voluntary)

Emergency Action/Fire Prevention Plan (1910.38 & 39)

  • A. Does the site have a written Emergency Action or Fire Safety Plan?

  • B. Does this site have a Fire Protection Plan?

  • C. Does the facility have an emergency alarm system whereby all associates can be notified of the emergency?

  • D. Have associates been trained on the elements of the Emergency Action/Fire Protection Plan, including those who have the responsibility of assisting in the safe and orderly evacuation of associates?

  • E. Is there a means to assure that all associate alarm systems are maintained in operating condition?

  • F. Is there a procedure for ensuring the adequacy and reliability of emergency alarms in the workplace? Auditor Note: A Supervised system (panel controlled alarm) must be checked annually; an Unsupervised system (manual alarm) must be checked every two months.

  • G. Are all the fire extinguishers charged and within the expiration date? Are fire extinguishers and hoses inspected and documented monthly?

  • H. Are the fire extinguisher inspection tags marked every month?

  • I. Is the facility using a supervisor "tag" or similar notification system for fire protection equipment impairments?

  • J. Has the location conducted fire drills on each shift at least once per year?

  • K. Is an updated evacuation plan posted in each area of the facility, identifying evacuation routes, and the location of each fire extinguisher?

  • L. Does the location have a designated reorganization point and are associates aware of the location of the reorganization point in the event of an emergency evacuation?

  • M. Are all exits clearly marked and lit?

  • N. Are all emergency aisles kept clear of debris?

  • O. Is the Sprinkler Main easily accessible?

  • P. Is the Sprinkler Main Valve chained open?

  • Q. Are all sprinkler heads free and clear?

  • R. Has the local fire department toured the facility for a pre-fire orientation? When?

Fire Extinguishers (1910.157)

  • A. Are portable fire extinguishers provided for associate use?

  • B. Are portable extinguishers properly mounted and identified?

  • C. Are fire extinguishers and hoses inspected and documented monthly?

  • D. Are fire extinguishers serviced annually by an outside firm, tagged with dates and identities of the person and/or firm performing service?

  • E. Have all associates been trained annually on the principles of fire extinguisher education and the hazards involved?

Flammable and Combustible Liquid Storage (1910.106)

  • A. Are flammable/combustible liquids stored in UL/FM approved cabinets?

  • B. Are large (drum) quantities of flammable or combustible liquids or gases stored in properly designated rooms?

  • C. Are safety containers used to transfer flammables?

  • D. Are the containers holding flammable/combustible liquids properly bonded and grounded?

  • E. Are all gas cylinders stored properly? (Auditor's Note: See notes in audit workbook)

Confined Space Entry/Rescue (1910.146)

  • A. Has the facility developed a Confined Space Entry Program that includes: list of confined spaces, specific entry procedures, procedure for atmospheric monitoring, procedure for pre-entry checks, role of entrants & standby attendant, entry permits, and procedure for rescue.

  • B. Have procedures been developed to conduct a pre-entry review with contractors? Copies of contractor employee training records? Discuss entry program to be followed? Review specific entry procedures for space to be entered? All aspects of the entry and required compliance to do the entry?

  • C. Are the confined space/permit space areas appropriately labeled?

  • D. Are contractor Confined Space entry tags/permits utilized for only one shift and filled out appropriately? (Verify by checking a representative number of completed permits).

  • E. Are contractor Confined Space Entry tags/permits being retained by the facility for one year and has the facility conducted an annual review of the confined space program to ensure that proper procedures are being followed?

  • F. Are employees trained annually about how to recognize a confined space and knowledge that MCC employees will not enter any confined space, with records kept on file?

Lockout/Tagout (1910.147)

  • A. Does the facility have a current written Energy Control (Lockout/Tagout) Program? a. Have procedures been developed, documented and utilized for control of hazardous energy. b. Do the energy control procedures clearly and specifically outline the scope, purpose, authorization, rule & techniques to be used. c. Is there a specific statement of the intended use. d. Are there steps for shutting down, isolating, blocking & securing machine. e. Are there steps for placement, removal & transfer of lockout / tagout devices.

  • B. Are there individual written procedures for multi-energy source machines/processes? Do procedures include a verification to ensure that all energy sources have been de-energized?

  • C. Are individual written procedures for multi-energy source machines/processes reviewed annually or prior to the next assigned lockout when it is over a year old?

  • D. Are lockout devices available and used in all cases where lockout is possible?

  • E. Are lockout devices and tags singularly identified within the facility by specific color, shape or size?

  • F. Are lockout devices and tags not used for other purposes such as out-of-service?

  • G. Do all authorized associates use tags and individual locks?

  • H. Do lockout and tagout devices indicate the identity of the associate applying the device(s)? Are the tags legible and understandable?

  • I. Do LOTO locks have single keys?

  • J. Do all tags have dates? (Dates are not required when picture tags are used.)

  • K. Have all associates who lock or tag out equipment (Authorized) received documented training on the purpose, procedures, and function of the Lockout / Tagout Program & verification?

  • L. Have all associates who operate equipment in an area where lockout/tagout is being performed (Affected) received documented training on the purpose and use of the energy control procedure?

  • M. Is there retraining provided for all authorized associates whenever there is a change in job assignment, change in machine, equipment or processes or change in energy control procedures?

  • N. Is a periodic inspection of the Energy Control specific procedures being conducted and documented at least annually? NOTE: Unless its subsidiary EHS management has specified a different number, each department of a facility that performs lockout/tagout shall conduct at a minimum at least two periodic inspections per month. Subsidiaries that do not have multiple departments that perform lockout/tagout should conduct a minimum of two periodic inspections per month at each facility.

Electrical Safety-Related Work Practices (1910.331-.335)

  • A. Has documented training been provided to those qualified associates facing a higher than normal risk of an electrical accident?

  • B. Has documented training on general electrical safety been provided for all other unqualified associates?

  • C. Are all panels and breakers accurately and clearly marked to indicate purpose?

  • D. Is a minimum of 36" clearance maintained in front of all electrical panels?

  • E. Are all cabinets and boxes intact with all knockouts and covers in place?

  • F. Are flexible extension cords being used properly (Temporary use only)?

  • G. Is MCC Electrical Safety Program being used (PPE, Permits, Training, etc.)?

  • H. Is the voltage and ARC Flash labels on each panel?

  • I. Does the facility have appropriate PPE for performing high voltage work? Verify that the required PPE meets requirements: e.g. 100 cal suits.

  • J. Has the facility PPE matrix been updated with high voltage PPE requirements: e. g. high voltage gloves, face-shields, head protection and especially 100 cal suits.

  • K. Is facility electrical PPE (gloves, sleeves, blankets, etc.) subjected to periodic electrical tests conforming with Tables I - 5 and I - 6 ? Auditor Note: Reference 29 CFR 1910.137 (b) (2) (viii) and (xii).

  • L. Are these required tests certified by the employer to include the identity of the equipment that passed the test and the date of the test? Reference 29 CFR 1910.137 (b) (2) (xii).

Powered Industrial Trucks (1910.178), Scissor Lift (1910.29), and Aerial Lifts (1910.67)

  • A. Does the PIT training program include formal classroom instruction (i.e. lecture, discussion, interactive computer learning, video tape, written material), and practical training (demonstrations performed by the trainer and practical exercises by the trainee)?

  • Does the training program include an evaluation of the operators performance in the workplace?

  • Does the training program include the specific hazards of operating the particular type of forklift, including manufacturers operating instructions?

  • Does the training program include reviewing the requirements of the OSHA standard (29 CFR 1910.178)?

  • Are the training and evaluations certified? (must include operator name, date of training, date of evaluation, name of instructor)

  • Was the training provided by persons who have the knowledge, training, and experience to conduct this training and evaluation?

  • B. Have current forklift operators been determined to be competent to operate a PIT, as demonstrated by successful completion of an evaluation program?

  • C. Is an evaluation of each operators performance conducted at least every three years?

  • D. Does the facility truck loading and unloading procedures require the use of trailer stabilizing jacks(jack stands)?

  • E. On those PIT’s that are equipped with seat belts, does the facility require the operators to wear seat belts?

  • F. Are pre-shift forklift checks being conducted? (Only required prior to use on that shift.)

  • G. Is air released on air-ride suspended trailers before the trailer is loaded? Is this included in the written dock procedures?

  • H. Does the facility retrain associates if the operator is involved in an accident or near-miss incident, or the operator was observed operating the vehicle in an unsafe manner, or is assigned to operate a different type of vehicle?

  • I. Is the forklift in good working order? (load backrest, seat belt, propane tank installed correctly, testing laboratory approval sticker, nameplates/stickers legible, etc.)

  • J. Are areas where forklifts travel identified with markings on the floor, signs, etc.?

  • K. Are all LP tanks stored properly? (Auditor's Note: See notes in audit workbook)

  • L. Is the storage area properly marked? (i.e. DANGER - Flammable Propane - No Smoking)

  • M. Is an emergency wash station located within 10 seconds walking of the forklift battery charging station? (ANSI Z258.1 - Emergency Wash Stations)

  • N. Do all PITs have the blue safety lights installed?

  • Auditor Note: A scissor lift is a mobile scaffold for which the platform only moves vertically. An aerial lift is any vehicle-mounted work platform that can move vertically and/or horizontally.

  • O. Is there a lift inspection that must be completed prior to use? Are the inspections documented and filed?

  • P. Is specific lift training completed for associates using the lifts, to include fall protection training?

  • Q. Is fall protection worn and attached to the boom or basket when working from an aerial lift?

Medical and First Aid (1910.151)

  • A. Does the facility have an emergency response team?

  • If no, does the location have at least two associates per shift trained/certified in first aid and CPR?

  • B. Is outside emergency responose help within 4 minutes of the facility?

  • C. Does this location have a written plan on responding to a medical emergency?

  • D. Are the phone numbers of emergency response organizations posted in a prominent area?

  • E. Does the facility have an Emergency "Red" bag to be used by trained team members during an emergency requiring medical attention more than first aid?

Automatic External Defibrillators (1915.87 Appendix A)

  • A. Does the facility provide an automated external defibrillator (AED)?

  • B. Are their trained designated employees for use of the AED on all shifts?

  • C. Is the AED located so they can be utilized within three to five minutes of a report or accident?

  • D. Do you have an inspection, testing and PM program developed in accordance with the manufacturers instructions?

Blood borne Pathogens (1910.1030)

  • A. Does the facility have associates, who are required by their job duties, to have potential exposure to blood borne pathogens?

  • B. Does the location have a written Exposure Control Plan that includes Exposure Determination?

  • C. Is there an annual review process to ensure the facility exposure control plan is current?

  • D. Are the containers used for disposal of contaminated sharps closable, puncture-resistant, and leak-proof on sides and bottom?

  • E. Are the containers used for disposal of contaminated materials red in color or labeled with the biohazard symbol?

  • F. Are the containers used for disposal of contaminated materials and sharps located as close as feasible to the immediate area of discovery?

  • G. Have Hepatitis B vaccinations been offered and documented to all associates with potential occupational exposure free of charge?

  • H. Do you have established guidelines to offer the vaccine to new associates within 10 days of their initial assignment?

  • I. Was the mandatory Vaccine Declination, found in Appendix A of the Standard, used?

  • J. Is annual training provided by, and documented by a person knowledgeable in all elements of the standard?

Eyewash/Shower Stations (ANSI Z358.1)

  • A. Are eyewash and shower stations located at least 10 seconds walking time from the location of all potential chemical hazards?

  • B. Is a drain, mat, or other water collection device provided under the stations to prevent creating a slip hazard if the stations are used?

  • C. Have all associates been trained on the location and proper use of emergency wash stations, as well as what to do if an associate must use the station?

  • D. Are eyewash and shower stations tested monthly, with the date of the test maintained on a card at the stations?

  • E. Are eyewash outlet heads protected from airborne contaminants with removable covers/caps?

  • F. Are the emergency wash stations clearly identified with a highly visible sign?

  • G. Is the space around the stations (48" in front, 30" wide) clear of debris and obstruction?

Walking-Working Surfaces - Ladders (29 CFR 1910.23 and 29 CFR 1910 Appendix D)

  • A. Does this facility use fall protection for any work at least 4 ft. above a lower level?

  • B. What types of fall protection equipment or devices are used?

  • C. Have any fixed ladders been installed (new or replacement) since 1/1/2018?

  • If yes, does it extend more than 24 feet?

  • If yes, does it have a ladder safety system or personal fall protection system?

  • D. Do all fixed ladders installed prior to 1/1/2018 have a cage, well, ladder safety system or personal fall arrest system?

  • E. Are pre-use inspections being completed on portable ladders?

  • F. Does the location routinely complete a Ladder Inspection Checklist for each ladder?

  • G. Are mechanisms used to keep ladders stationary when being stored?

  • H. Is any ladder with structural defects immediately tagged "Do Not Use" and taken out of service or replaced? (1910.145 and 1910.22(d))

  • I. Are each of the portable ladders in the location individually numbered?

Cranes/Hoists (1910.179)

  • A. For cranes and hoists such as jibs, monorails or other overhead lifting equipment, has inspections been completed and documentation on file? AUDITOR NOTE: An annual inspection, periodic inspections should have documented load testing.

  • B. Are cranes/hoists operated by trained personnel?

  • C. Are operators making daily visual inspections prior to each use?

  • D. Are monthly inspections being conducted by a qualified inspector and are these inspection records on file?

  • E. Are the annual inspections completed by a qualified outside crane inspector with documentation?

  • F. Is there a PM program based on the crane/hoist manufacturer's recommendations?

  • G. Are synthetic slings and under-the-hook apparatus maintained in serviceable condition? NOTE: check for red indicator "wear" threads on synthetic slings.

  • H. Is the capacity of the crane/hoist clearly marked?

Hot Work (1910.252)

  • A. Is a formal Hot Work Program in place?

  • B. Are all Hot Work Permits retained for a minimum of 48 hours?

  • C. Is training completed and documented?

Industrial Hygiene Sampling (1910.1029 Appendix B)

  • A. Is industrial hygiene sampling done for any specific chemicals in the facility?

  • If yes, what chemicals are being monitored for?

  • If yes, do you have a monitoring plan in place?

Chromium VI (1910.1026)

  • A. Has the facility determined the 8 hour Time Weighted Average for each employee with the highest potential exposure to Chrome VI? EXAMPLE OF EXPOSURE: Welding on stainless steel with MIG or stainless steel welding rods. AUDITORS NOTE: If they have, then go to secondary list of chromium questions.

Machine Guarding (1910.212)

  • A. Are safeguards in place and meet the OSHA requirements?

  • B. Do the safeguards prevent workers hands, arms, and other body parts from making contact with dangerous moving parts?

  • C. Are the safeguards firmly secured and not easily removable?

  • D. Do the safeguards ensure that no objects will fall into the moving parts?

  • E. Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?

  • F. Can the machine be oiled without removing the safeguard?

  • G. Are LOTO procedures followed before removing a guard?

  • H. Are all E-stops used for emergency stopping of hazardous machines, red? (1910.144)

Laser Safety (ANSI Z136.1 - 2007)

  • A. Does the facility have laser(s) and or laser equipment labeled by the manufacturer as a hazard class 2M, 3B, or 4? (This can be determined by looking at the manufacturer equipment labels.)

  • B. Are facility laser safety programs and employee training programs provided for Class 3B or Class 4 lasers and laser systems? Auditor Note: Employer and/or facility safety programs and employee training should be provided for laser systems containing embedded Class 3B and Class 4 lasers.)

  • C. Is there a designated individual as the Laser Safety Officer (LSO) with the authority and responsibility to effect the knowledgeable evaluation and control of laser hazards, and the implementation of appropriate control measures, as well as to monitor and enforce compliance with required standards and regulations.

  • D. For installed lasers, have manufacturers warning labels been maintained and are they visible to observers?

  • E. Have there been any injuries or laser related incidents and records maintained on these incidents?

  • F. Have appropriate medical examinations and medical surveillance program been completed?

Asbestos (29 CFR 1910.1001, 1101)

  • A. Does the facility have any known or suspected asbestos containing material? Was a survey completed and documentation kept to confirm?

  • B. Is there an asbestos plan or procedures developed explaining the location, management, method and responisbility for the asbestos containing material in the event of the material being disturbed or abatement is needed? Does the plan state that a certified outside contractor will be used to remove all asbestos continaing material when needed?

  • C. Are associates notified and trained annually on the location and managment of the asbestos containing material?

Contractor Safety

  • A. Are all associates responsible for monitoring on-site contractors aware of the written EHS Contractor Program?

  • B. Has a contractor safety packet been issued and a signed returned copy retained on file?

Miscellaneous Items (General Duty Clause or other)

  • A. Is the facility neatly organized?

  • B. Are the floors maintained and free of debris?

  • C. Does the facility use "wet floor" signs when needed?

  • D. Are aisle ways or doorways blocked?

  • E. Are exit signs appropriately placed?

  • F. Does all compressed air lines have a safety nozzle that have a built in pressure reducer or relief device that reduces the air pressure in case the nozzle is dead ended? 30 psi or less

  • G. Are items in the plant stored and stacked securely to prevent falling, sliding, or collapsing? Items on top racks should be banded or shrink-wrapped for security from falling.

  • H. Are storage areas kept free from accumulation of materials that constitute hazards from tripping, fire, explosion, or pest harborage?

  • I. Are clearance limits marked for the proper height of stacked objects?

  • J. Is there an 18" clearance between the top of the racked or stacked material and the sprinklers?

  • K. Are rack columns anchored to the floor?

  • L. Are cross beams bolted to the uprights?

  • M. Are load ratings present on racking?

  • N. Is there a maintenance and inspection program for storage racks? The program should include keeping aisles clear and providing sufficient clearance for material handling equipment. Also, ensuring racks are properly aligned, plum, and level, per manufacturer’s instructions.

Section II - Environmental Regulations and Compliance

Water: Pollution Prevention and Control (40 CFR...part 112 and parts 405-471)

  • Does this facility have a water permit (NPDES)? Review permit

  • A. Is this facility in compliance with the requirements of this permit?

  • B. Does this facility have a Storm Water Pollution Prevention Plan?

  • Does this facility have a waste water discharge permit? Review permit

  • A. Is this facility in compliance with the requirements of this permit?

  • B. Are waste water analysis reports required and being submitted to local authorities?

Air Permitting (40 CFR 70)

  • Is this facility required to have a Title V or other permit per state or federal regulations? Review permit

  • A. Is this facility in compliance with the requirements of this permit?

  • B. Does the facility notify the local regulatory authority whenever new emission points are added or substantial changes to the facility’s process occur?

Greenhouse Gas Reporting (40 CFR Part 98)

  • Is this facility required to report based on the Greenhouse Gas Program?

  • A. Does this facility emit 25,000 metric tons or more of carbon dioxide equivalent per year?

  • B. Does the faciity have documentation of reporting annually by March 31 for emissions in the previous calendar year?

Boilers and process heaters (40 CFR 65.149)

  • Does this facility have a boiler or process heater?

  • A. Is the boiler permit current and displayed?

  • B. Does the facility have records of inspections and repairs?

  • C. Is this facility in compliance with the requirements of this permit or any other affiliated permit?

Hazardous Waste Management (40 CFR 260-355)

  • Does the facility have RCRA trained associates?

  • Does the facility have DOT trained associates and are they the only ones handling HW or signing manifests?

  • A. Has a hazardous waste determination been determined for wastes generated at this facility?

  • B. Is this facility a CESQG, SQG, or LQG?

  • C. Is the facility registered as a hazardous waste generator and does the registration list the correct waste streams?

  • D. Is the facility following the manifest system, with all shipments of hazardous waste documented on a uniform haz waste manifest and LDR?

  • E. Do you have the last three years of manifest plus current?

  • F. Are all hazardous waste containers properly labeled, dated, closed and maintained in good condition and inspected weekly?

  • G. Does the facility use a registered hazardous waste transporter to ship hazardous waste off-site?

  • H. Are all hazardous wastes stored on-site for no longer than the maximum accumulation time frames?

  • I. Are all personnel responsible for managing hazardous waste trained in hazardous waste handling and emergency response procedures?

  • J. Are all records pertaining to emergency preparedness, associate training, waste shipments, annual reports and required facility inspections maintained at the facility?

  • K. Are all hazardous wastes shipped off-site sent to a permitted hazardous waste facility?

  • L. Does the facility have a RCRA permit or interim status for all on-site treatment, storage or disposal units?

  • M. Has an audit of the current waste facility(s) been completed.

  • N. Is this facility completing all required reporting: annually or biannually?

  • O. Has the facility had any violations in the past 3 years?

Universal Waste (40 CFR 273)

  • A. Does the facility collect batteries, lamps, aerosols, or mercury containing equipment to send out as universal waste?

  • B. Is this waste sent out no more than one year from start date?

  • C. Is the waste labeled correctly, "Universal Waste, Lamps", "Used Lamps", or "Waste Lamps"?

  • D. Are broken lamps treated as hazardous waste?

  • E. Is proper documentation kept for the collection and transportation of the universal waste?

Used Oil (40 CFR 279)

  • A. Does this facility follow the used oil generator rules?

  • B. Are drums/tanks kept in good condition and are labeled properly, "Used Oil"?

  • C. Is proper documentation kept for the collection and transportation of the used oil?


  • A. Does the facility routinely review the industrial waste, the municipal solid waste, for reuse or recycling?

Underground Storage Tanks (40 CFR 280)

  • Does the facility have underground storage tanks?

  • A. Do the USTs have release detection?

  • B. Does the USTs have pressurized piping?

  • C. Does the USTs have suction piping?

  • D. Are repair, monitoring and all testing records kept for at least 1 year?

  • E. Are records kept for at least 5 years of calibration and maintenance of release detection equipment?

  • F. Are vendor performance claims and results of third-party evaluations kept for 5 years?

  • G. Do the USTs have corrosion protection?

  • H. Are there records for cathodic protection?

  • I. Does the UST have spill protection equipment, such as catchment basin?

  • J. Does the UST have overfill protection? Automatic shutoff? Alarm?

  • K. Have all required notifications been made to local, state or federal agencies, if required?

Aboveground Storage Tanks (40 CFR 112)

  • Does the facility have aboveground storage tanks?

  • A. Is there any evidence of possible corrosion or cracking of the tank?

  • B. When was the last third-party tank inspection completed?

  • C. Do the tanks have sufficient secondary containment? Large enough to hold contents of largest tank plus 25 year storm event.

  • D. Is the containment structure in satisfactory condition? Do you have record of regular inspections?

  • E. Does the facility have a Spill Prevention, Control and Countermeasure Plan?

  • F. Have all required notifications been made to local, state or federal agencies, if required?

SARA Title III, Section 312 Tier II (40 CFR 370)

  • Is the facility required to report?

  • Has the location submitted either copies of SDSs or a list of SDS chemicals to the State Emergency Response Commission (SERC), Local Emergency Planning Committees (LEPC), and local fire department by March 1st?

SARA Title III, Section 313 (40 CFR 370)

  • Is the facility required to report?

  • Has the location completed TRI (Toxic Release Inventory) reporting, based on the toxic chemicals that are manufactured, processed or used over the course of a calendar year in excess of the reporting quantity by July 1st?

Hazwoper (Emergency Contingency Plan) (1910.120)

  • A. Has the facility developed and implemented an Emergency Contingency Plan or HazWoper Plan anticipating chemical emergencies? For facilities relying on outside resources, the written plan should be in the 1910.38 Emergency Action Plan. The HazWoper plan must include the following: a. Pre-emergency planning with outside parties. b. Personal roles, lines of authority, training, and communication. c. Emergency recognition and prevention. d. Safe distances and places of refuge. e. Site security and control. f. Evacuation routes and procedures. g. Decontamination. h. Emergency medical treatment and first aid. i. Critique of response and follow-up. j. PPE and emergency equipment.

  • B. If the facility may have situations where they will not have a fully manned emergency team, does the facility Emergency Control Plan or HazWoper Plan have procedures in place to cover use of outside agencies?

  • C. Does the facility have an up to date list of team members?

  • D. Does the facility have at least one Hazmat team per operating shift?

  • E. Is there at least one individual per shift assigned as an Incident Commander?

  • F. Is there documented evidence of annual HazWoper refresher training being performed for all team members?

  • G. Is there adequate chemical emergency equipment available, is it maintained in good working order and are periodic inspections performed regularly and documented?

  • H. Does the facility HAZMAT team participate in a practice response drill at least annually?

  • I. Does the Hazmat Team conduct critique sessions after responding to a spill/drill and are these critique sessions documented? Are critiques complete and have all follow-up actions been completed?

Section III - Security


  • A. Are facility entrances/exits secure?

  • B. Are sensitive documents secure?

  • C. Are keys issued and documented properly?

  • D. Are key fobs issued and properly documented (specifically to contractors)

  • E. Does parking lot have adequate lighting?

  • F. Does the shipping department have a security cage?

  • G. Do all contractors go through contractor safety; with sign-offs?

  • H. Are there camera's in the facility (interior/exterior)?

  • I. Bomb threat protocol accessible?

The templates available in our Public Library have been created by our customers and employees to help get you started using SafetyCulture's solutions. The templates are intended to be used as hypothetical examples only and should not be used as a substitute for professional advice. You should seek your own professional advice to determine if the use of a template is permissible in your workplace or jurisdiction. You should independently determine whether the template is suitable for your circumstances.