When you opened the daily mail, did you discover your company had received a dreaded notice of complaint (NOC) from OSHA? With the very short response time OSHA typically allows, you are likely already scrambling for answers. But, with the help of a consultant or contractor, you may be able to spare yourself and your company from much of the enigma involved in dealing with OSHA. Based on CTI’s 30 years of trusted experience, here is an easy to follow OSHA NOC action plan that we have created for you:

1. Take a couple deep breaths

This may be unexpected and the letter will certainly be accusatory; but, stepping back for a moment will help you make levelheaded decisions and avoid further escalating the conflict with OSHA. Calling OSHA right away or hammering your employees for information, will not result in a positive outcome.

2. Do an internal investigation

Open and honest communication within management is the key to figuring out how to deal with the NOC. Show sincere concern by asking if anyone can identify a potential source of the problem (while avoiding the natural desire for finger-pointing). You may discover the complaint is caused by odors/gasses coming off a tank, shortcuts that have created unsafe work practices, or areas in your workplace that you know have been neglected.

3. Locate any info on the regulation

Both the applicable OSHA and EPA regulations are key to this investigation. If you have proof that the complaint is not a valid issue, you can use this evidence to convince OSHA that the alleged complaint is not accurate and requires no further follow up.

However, if you find that you do not have the necessary information, sampling data, or other important facts that can help your case with OSHA, you will want to hire a consultant.

4. Hire a consultant

A trusted consultant, like CTI, will be your biggest ally in dealing with your NOC. Resolving the alleged complaint will require some information from you:

  • Safety Data Sheets (SDS)
  • Number of affected employees
  • Length of shifts (exposure time)
  • Layouts of process areas
  • Engineering controls in the process areas

Consultants such as CTI work for YOU, the client, a non-disclosure agreement will put your mind at ease that the information you share with your consultant remains confidential.

Unfortunately, resolving most NOC’s are not as easy as 1, 2, 3. Getting compliant without incurring additional fines and scrutiny can be a difficult task, if tackled alone. Knowing who to reach out to during this time will help you achieve the safest and most economically sustainable solution. CTI knows how to serve its clients, and, especially in such an uncertain time, CTI can help ensure you have some much-needed flexibility when dealing with OSHA or other regulatory agencies. You will rest easier knowing you have entrusted your compliance issues to Compliance Technologies, the company with compliance built right into its name!

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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