The purpose of a safety and health inspection is to target specific operational, facility, or program deficiencies that may cause accidents, injuries, and illnesses, and to foster compliance with OSHA regulations and standards.
Safety personnel conducting inspections must be technically competent to recognize and evaluate hazards of the work environment and to suggest specific abatement procedures. They must use inspection checklists contained in the most current Safety Toolkit that reference current OSHA and other applicable regulations, standards, and Postal Service policies.
The area Human Resources manager must ensure that safety and health inspections are conducted as required by this section.
The area Human Resources function must conduct area inspections of plants or other installations as necessary to ensure effective safety and health programs. Inspection teams should consist of area and local safety and health, maintenance, and line management personnel.
Union representatives from the local safety and health committee may participate in inspections conducted by area safety and health personnel provided that the union represents employees at the facility being inspected. The number of union representatives will be determined by appropriate collective–bargaining agreements.
District and plant safety personnel must conduct a semiannual inspection of all installations with 100 or more work years of employment in the regular workforce and enter their inspection findings into the Safety Toolkit. If Headquarters or the area conducts an inspection, it serves as one semiannual inspection.
Inspection teams consist of personnel from Safety, Maintenance, In–Plant Support, and line management.
Union representatives from the local safety and health committee may participate in inspections referred to in this section, provided that (a) the union represents employees at the installation, and (b) the union representative is domiciled at the installation to be inspected. If that union representative is not domiciled at the installation to be inspected, and if that union represents employees at the installation, at the union’s option (a) representatives from the committee may participate in the inspection at no additional cost to the employer; or (b) the union may designate a representative domiciled at the installation to be inspected to participate in the inspection. The number of union representatives is determined by appropriate collective bargaining agreements.
Collateral duty FSCs must conduct an annual inspection of each installation with less than 100 work years of employment in the regular workforce. The FSC will conduct the inspection using instructions and an approved inspection checklist located in the Safety Toolkit or on the Safety Resources Page. FSCs must enter inspection findings into the Safety Toolkit if they have access to a Postal Service computer. District safety personnel provide technical assistance and support as necessary. In addition, district safety personnel must visit facilities as necessary to verify results of inspections by the FSC and provide assistance. If district safety personnel perform an inspection, it serves as the annual inspection.
Inspection teams consist of the collateral duty FSC and at least one supervisor.
Union representatives from the local safety and health committee may participate in the annual inspection of each installation with less than 100 workyears of employment in the regular workforce where the committee exists in the installation being inspected. In installations that do not have a safety and health committee, inspectors give a bargaining unit employee (from each union that represents employees in that installation) the opportunity to accompany them during these inspections. If the unions request it, the bargaining unit employees should be selected on a rotating basis by the exclusive bargaining representatives in that installation. The number of union representatives is determined by appropriate collective bargaining agreements.
Postal Service safety personnel are authorized:
- To conduct inspections without delay.
- To have access to all available information relevant to the occupational safety and health of the workplace to be inspected, including:
- PS Form 1767, Report of Hazard, Unsafe Condition, or Practice;
- PS Form 1769/301, Accident Report;
- PS Form 1772, Accident Log;
- OSHA Form 300;
- OSHA citations or other correspondence; training records; and
- All checklist and deficiency reports.
- To interview employees privately, if necessary.
- To consult with a reasonable number of employees during the inspection if there are no authorized representatives of employees.
- To deny the right of accompaniment to any person whose participation interferes with a fair and orderly inspection.
Members of the inspection team must conduct an opening conference with the installation head and the union representatives who are to participate in the inspection. The purpose of this conference is to explain the purpose and scope of the inspection and to inform the installation head that the inspection team will, in the course of inspection, consult with employees and managers as needed.
Safety inspections must be conducted according to the following rules:
- The responsible manager must ensure that the team, led by the senior safety professional (or collateral duty FSC) assigned, has adequate participation and resources to accomplish a meaningful inspection.
- Members of inspection teams must comply with all safety and health rules at each installation including the use of protective clothing and equipment. The conduct of inspections must not result in unreasonable disruption of operations.
- Representatives of Maintenance, In–Plant Support, Operations, and others designated by management as appropriate, must participate.
- During the course of an inspection, any employee must be afforded an opportunity to bring to the attention of the inspection team any unsafe or unhealthful working condition that the employee believes exists in the workplace. In order to speak with the head of the inspection team, employees must first request permission from their immediate supervisors. Such requests must not be unreasonably denied.
- Safety personnel must arrange for or conduct industrial hygiene evaluations and sampling and take photographs where necessary.
If imminent danger is identified, the inspector must immediately inform the official in charge of the workplace. The official in charge of the workplace must undertake immediate abatement of the dangerous condition and the withdrawal of employees who are not necessary for the abatement. If the official in charge needs assistance to undertake full abatement, he or she must immediately notify, through channels, the district manager, who provides assistance for the abatement effort. The area Human Resources manager is also to be notified.
Safety and health committees and union representatives of the employees affected must be informed of all relevant actions.
At the conclusion of a scheduled inspection, safety personnel must confer with the installation head and the union representative(s) who accompanied the inspection team and advise them of deficiencies disclosed by the inspection. Anyone at the conference may bring to the inspector’s attention any pertinent information regarding conditions in the workplace.
The team leader must enter inspection findings into the Safety Toolkit, generate the inspection report, and give the inspection report to the installation head/manager no later than 5 days after completion of the closing conference. In addition, the team leader sends copies of the report to the employee representative(s) who participated in the closing conference and/or to the local safety and health committee.
Immediately upon receipt of the deficiency report the installation head must post a notice in a prominent place where it will be readily observed by employees stating that the inspection has been received and is available for viewing in a convenient location, such as the safety office. The notice must indicate, as applicable, that deficiencies were found and describe any special procedures that are in place. The notice shall remain in place for 3 working days or until all items have been abated, whichever is longer. Copies of all inspections and reports will be maintained in the Safety Toolkit.
Safety hazards are classified as follows:
- Imminent danger — A situation in which there is a reasonable certainty of danger that could cause death or serious physical harm immediately or before the danger can be eliminated through normal abatement procedures.
- Serious danger — A situation in which there is a substantial probability that death or serious physical harm could result.
- Nonserious danger — A situation that has a direct relationship to job safety and health but probably will not cause death or serious physical harm.
Within 5 working days after receipt of the inspection report, a hazard abatement committee must be established and meet to assign priorities and specific abatement dates within the limits set by the inspection team. The installation head/manager must chair this committee. (Note: Postmasters or others who serve as installation heads for detached units may designate a chair for those detached unit abatement committees only.) Committee members must include:
- Installation head (or designee as noted above).
- Safety representative (collateral duty FSC if appropriate).
- Maintenance representative.
Additionally, Mail Processing, Customer Services, Industrial Engineering, Purchasing, and other personnel must attend when their functional areas are involved.
Where feasible, correct deficiencies within 20 days of receipt of the inspection report.
All deficiencies that are not corrected within 20 days must be reported immediately, along with a Hazard Abatement Plan (HAP), to the district manager with copies furnished to the manager, Post Office Operations, or the lead plant manager; the supporting manager, Safety; and manager, Human Resources, District. The HAP must contain the following:
- Name of the installation.
- Location of the unsafe condition.
- Description of the unsafe condition.
- Length of time the condition has existed.
- Explanation of the circumstances of the delay in abatement.
- A management action plan (MAP) that will be used for resolution of the problem.
- A summary of steps being taken in the interim to protect employees from being injured by the unsafe or unhealthful working condition.
Affected employees must be informed of the provisions of the plan.
The Safety Toolkit provides a HAP template and reports. This template must be used to develop the inspection–specific Hazard Abatement Plan.
All deficiencies that are not corrected within 45 days must be reported immediately, along with the HAP through management channels to the vice president of Area Operations, with copies to the area Human Resources manager and the area manager, Safety.
Once the HAP has been submitted, any changes in the plan require the submission of a new plan in accordance with the provisions of this section.
Once the HAP is created in the Safety Toolkit it is automatically updated as deficiencies are corrected. Managers with access to the Safety Toolkit can view the updated HAP by logging on to the Safety Toolkit.
Within 5 days of abatement, a copy of the abatement record, signed by the installation head/manager, must be sent to the safety professional in charge of the inspection.
When deficiencies are corrected (hazards abated), the FSC or supervisor/manager responsible for the abatement must enter the abatement date for the deficiency in the Safety Toolkit. For facilities that do not have access to Postal Service computers, the installation head/manager must provide a copy of the abatement record to the supporting manager, Safety, within 5 days of completion of the abatement action.
When deficiency correction requires action by the General Services Administration or another federal lessor agency, the installation head/manager must contact the lessor agency and request corrective action. This does not, however, relieve management from the obligation to protect employees by implementing effective interim controls.
The procedures for correcting a deficiency must include a process to check (through spot checks and re-inspections as appropriate) whether the corrective action taken has proven to be effective.
Spot checks and re-inspections should be conducted by the same personnel (i.e., full-time safety personnel or FSCs) who performed the original inspection, if possible. Posting of the follow-up inspection results is not required.
The area vice president may designate an Area-sponsored re-inspection following submission of a HAP to the Area.
PS Form 1767 is designed to encourage employee participation in the Postal Service safety and health program and to provide prompt action when employees report a hazard. This form provides a channel of communication between employees and management that promotes a prompt analysis and response with corrective action to reports of alleged hazards, unsafe conditions, or unsafe practices.
Supervisors must maintain a supply of PS Forms 1767 in the workplace in a manner that provides employees with both easy and (if desired) anonymous access.
Any employee, or the representative of any employee, who believes that an unsafe or unhealthful condition exists in the workplace may do any or all of the following:
- File a report of the condition on PS Form 1767 with the immediate supervisor and request an inspection of the alleged condition.
- If the employee desires anonymity, file PS Form 1767 directly with the installation’s safety personnel, who will immediately give the report to the employee’s supervisor for necessary action. (In such cases, safety personnel must not disclose the name of the individual making the report.)
- Report alleged unsafe conditions to a steward, if one is available, who may then discuss the condition with the employee’s supervisor.
Discrimination against an employee for reporting a safety and health hazard is unlawful.
The immediate supervisor must promptly (within the tour of duty):
- Investigate the alleged condition.
- Initiate immediate corrective action or make appropriate recommendations.
- Record actions or recommendations on PS Form 1767.
- Forward the original PS Form 1767 and one copy to the next appropriate level of management (approving official).
- Give the employee a copy signed by the supervisor as a receipt.
- Immediately forward the third copy to the facility safety coordinator.
It is the supervisor’s responsibility to monitor the status of the report at all times until the hazard is abated. If the hazard remains unabated longer than 7 calendar days, the supervisor must verbally inform the employee as to abatement status at the end of each 7–day interval.
The approving official (the responsible manager) must initiate action to eliminate or minimize the hazard.
- If this results in the submission of a work order, attach the original PS Form 1767 and forward it, through channels, to the manager of Maintenance.
- If the approving official determines that there are no reasonable grounds to believe such a hazard exists, the employee must be notified in writing within 15 calendar days. (Safety personnel must assist in this determination when requested.)
- If the hazard was abated through actions of the approving official:
- The employee must be notified in writing, and
- The original PS Form 1767, with a statement of actions taken, must be forwarded to the safety office.
Safety personnel assigned to plants and FSCs must log and sequentially number all hazard reports received on PS Form 1773, Report of Hazard Log, or if the FSC has computer access, enter the reports into the Hazard Log Module of the Safety Toolkit. Safety personnel and FSCs must also review all PS Forms 1767 for accuracy, completeness, and follow–up, as necessary. They must routinely provide status reports of PS Form 1773 logs and Safety Toolkit reports at executive and Joint Labor–Management Safety and Health Committee meetings (or regular staff meetings in facilities with fewer than 50 employees).
Maintenance must notify the approving official when any PS Form 1767 maintenance–related work order has been completed.
Installation heads/managers are responsible for responding promptly to hazard reports and ensuring that line supervisors are diligent in correcting hazards. If a hazard report indicates that imminent or serious danger exists, the installation head must take immediate corrective action.
