1. Review all Company OSHA/IOSHA citations (at any site of work) for the past several years to determine whether any abatement or corrective actions are necessary at any Company plant or site of work (including construction sites, for construction industry employers). Taking prompt corrective actions may be helpful in defending alleged "Willful," "Knowing," "Repeat" and/or "Failure to Abate" citations issued by OSHA/IOSHA. Indeed, a failure to correct such hazards can result in these types of citations being issued. Most importantly, uncorrected hazards may result in serious employee injuries and accidents.
  2. Perform prompt employee training and retraining, especially with respect to specific worksite hazards. This is especially important prior to peak production periods or business up cycles.
  3. Perform a review of all new and old equipment to ensure that such equipment remains fit for use and that employees are very familiar with safety precautions, required personal protective equipment and operating instructions (including understanding of any owner's and operator's manuals).
  4. Consider performing a safety audit of the worksite, but consult your Company lawyer before doing so and before putting anything in writing about a proposed safety audit. There may be considerations about attempting to handle the audit in connection with the attorney/client privilege and/or work product protections. Also, promptly take corrective actions suggested by any such audit. A failure to do so may not only involve uncorrected safety deficiencies, but such failure may result in very high penalties associated with alleged "Willful" or "Knowing" violations.
  5. Ensure enforcement of safety policies and rules by training/retraining supervisors and managers to: 1) be proactive in reviewing operations for adherence to safe work practices and OSHA standards; and 2) take and document prompt corrective action (including disciplinary action, if necessary) to address unsafe work performance.