in reviewing the report should determine the reasonableness of the suggested correction and the necessity of including it in the written notice of violation. Time limit for compliance. It is essential that a predetermined time limit should be set for compliance in the case of each safety and health violation. In some States the inspector is given authority to use his own judgment in recommending the time limit for compliance, basing it on the nature and extent of the needed correction. The inspector's recommendation, as indicated on the regular inspection report, is then submitted to the inspection division for review before it is incorporated in the notice of violation issued to the employer. In other States a specific time limit of 10, 20, or 30 days has been prescribed for specific types of violations. It will be necessary for each State to determine which method is best adapted for its particular conditions. In the case of hours, minimum wage, and child-labor laws, the enforcing agency does not usually have the authority to authorize an extended time limit for observance of the law. Appeals from notice of violation.-The inspector should not suggest appeals from notices of violation, but upon request should furnish information as to how appeals may be made under the provisions of the law. 2. SAFETY AND HEALTH Although it is not the intent of this Manual to recommend safety and health standards, a description of inspection procedure must unavoidably suggest certain general minimum regulations. It will be necessary, of course, for the inspection division of each State to guide the inspector with more complete standards embodying any specific legal requirements peculiar to that State. The inspector in his role of a safety adviser should make it his duty to advise each establishment in respect to any safety and health hazards regardless of whether or not there are any specific State statutes, rules, or regulations covering such hazards. In general, therefore, the procedure suggested here should be applicable in any State. As stated under subsection A-1-d (see p. 25) no definite general order of inspection can be recommended since it will necessarily vary with each establishment, according to such factors as its size, nature of business, adequacy of records, and attitude of employer. Usually, in the case of inspection for safety and health, the inspector would first examine the appropriate records and then make the survey of the building itself, its physical structure, exits, and sanitary facilities, and then follow through with the inspection of the machinery, equipment, and processes in the order of the "flow sheet" or schedule of operations; that is, follow each process in its proper sequence from the time the raw materials are received to the storage of the finished goods. a. Plant accident records. (1) Adequacy.—The plant-accident records should be reviewed by the inspector with the employer. The employer should keep complete records of all accidents including a description of how each accident occurred, the type of accident, department, occupation, injury suffered, and disposition of case. Firstaid cases or nondisabling injuries should be recorded and reviewed because the circumstances causing these, if not corrected, may produce more serious injuries. At the end of each month the plant management should summarize, study, and compare its accident experience in whatever detail meets its condition best. sure; expressed by the formula: Frequency rate Severity rate means the total time charges, as the result of disabling injuries, per thousand man-hours of exposure; expressed by the formula: severity rate equals Total time charges X1,000 For example, if the 5 injuries, mentioned above, (2) Frequency and severity rates. In addition to recording the facts on each individual injury, it is essential that disabling injury records should be expressed in terms of fre- would be quency and severity rates in order to permit a comparison with the plant's record for previous periods and with the record of other similar plants and of the industry as a whole. The rates may be computed for 1 year or for any other period of time or for any particular job. Frequency rate means the number of disabling injuries per million man-hours of expo or 8. [Upon request, the Division of Labor Standards, United States Department of Labor, will furnish more complete information regarding the definition of these terms and the use of accident frequency and severity rates.] (3) Reporting of injuries.-The inspector should note whether or not all injuries required 30 REGULAR INSPECTION PROCEDURE-SAFETY AND HEALTH by law to be reported to the workmen's compensation agency have been reported and whether or not these have been investigated by the inspection division. The Manual Committee has recommended the obligatory reporting of industrial injuries and diseases to the proper State agency as a basic factor in the reduction of accidents. About one-half of the States now require reports of all such injuries. Nearly one-fourth of the States require the reporting of injuries causing disability of 1 day or more, and in the remaining States, the provision varies from the reporting of those causing disability of 2 days or more to 2 weeks or more. (4) Number of employees.-Before proceeding with the inspection of the plant itself, the inspector should have a record of the number of male and female employees located on each floor in order to determine compliance with the requirements for the sanitary facilities and exits. (See Explanatory Statement accompanying Building Survey forms, p. 129.) b. Posting requirements. In addition to observing the required posting of the law, rules, or regulations the inspector of the law, rules, or regulations the inspector should check, whenever the law requires it, the posting of elevator and boiler certificates, notice of coverage under the Workmen's Compensation Law and Unemployment Compensation Law, certificates of occupancy, smoking permits or smoking prohibited notices, certificates or licenses for the operation of special industries, such as bakeries and dry-cleaning and dyeing establishments and any other posting requirements. The inspector should record on his inspection report the nature of any violations of such posting laws. c. Sanitation. (1) Housekeeping.—(a) Importance in preventing accidents.-Housekeeping is a term applied to the general cleanliness and orderliness of the entire plant. It is an important factor in preventing accidents, both directly and indirectly. Unclean floors and materials not arranged in their proper places may cause a serious or fatal injury. Also, careless housekeeping practices make careless workers and [10/25/37] thus indirectly may cause many other types of accidents. Cleanliness and orderliness are vital both to the safety of the workers and to the efficiency of the plant. (b) Time, frequency, and method of cleaning.— Work benches or work places are more usually kept clean for production reasons, but dust and dirt may be allowed to accumulate on the walls, the overhead beams and trusses, fixtures of different kinds, pipes, electrical conduits, and ventilators. The dirt may also accumulate in corners of rooms and in connection with discarded containers and wrappings and with the storage of materials. Whenever possible it is recommended that cleaning should be done outside of regular working hours. The frequency of cleaning should depend on the type of plant and nature of work performed. Daily cleaning of an entire plant may be absolutely necessary in some cases. Adequate precautions should be observed to prevent redistribution of dust into the plant atmosphere. The well-painted plant is conducive to good housekeeping. By painting the accumulation of dirt in such places and discorners white, some establishments avoid the courage the spitting of tobacco juice there. In sawdust and placed in convenient locations are some plants disposable cuspidors filled with provided. The inspector should note the adequacy of the (c) Adequacy of waste disposal methods.methods of disposal of factory wastes; that is, those materials rejected in the various steps of processing or manufacturing of a finished article. This is reflected by the housekeeping in and about the plant. Tidy and neat plants are free from accumulations of waste. quently plants will install adequate methods of disposal but fail to maintain these methods in a good state of repair. Attention should be given to the ultimate disposal of such waste to make sure that another hazard is not created. Fre (d) Protection against insects and rodents.Adequate screening should be provided for all In the case of all industries preparing or handling foodstuffs, the premises should be adequately screened and rat-proofed. service rooms, particularly lunch rooms and dation as to the type of toilet with which the toilet and wash rooms. plant should be equipped. Toilets also may be too closely situated to eating facilities or, on the other hand, may be located so far away in the plant that a worker must leave his work for long periods of time in order to use them. It is important that washing facilities should be located contiguous to toilet rooms. In the case of those industries located in mosquito-breeding territory, attention should be given to stagnant or open pools of water or open containers. Where these breeding places cannot be eliminated by drainage or covering during the mosquito-breeding season, the surface should be treated in a manner approved by the health authorities to prevent mosquito breeding. (e) Other housekeeping items subject to inspection.-Racks or holders to keep tools when not in use should be provided to encourage good housekeeping. Aisles, floors, overhead platforms, and passageways, should be kept free of loose materials and articles. The painting of lines on the floor to define aisles and passageways is recommended. Holes and uneven or loose boards, and all dangerous projections such as nails and splinters should be eliminated from floors, stairways, and other walkway surfaces. The inspector should observe also whether materials are piled so that they will not fall easily or be displaced by vibrations or jolts. (2) Toilet facilities.-(a) Number, type, and location.-Frequently States designate the number of toilets that should be furnished for a certain number of male and a certain number of female employees. An adequate number conveniently located and affording privacy not only for each sex but for each individual should be provided. Entrances should be plainly designated and properly screened. It is not unusual to find plants completely lacking in toilet facilities, or if not completely lacking, supplied only with the more primitive types such as the outdoor toilet. When located out of doors, it may mean that employees engaged in high-temperature processes must pass from a heated atmosphere out through cold weather in the winter time to these toilets. Where there are no contra-indications, employers should be encouraged to provide inside toilets. Usually each State or municipality has, if not a specification in the law, at least a recommen (b) Illumination.-Toilet rooms, of course, should be well illuminated, both by adequate window space and by proper artificial lighting. It is recommended that the walls should be well painted in a light color. (c) Ventilation.-Adequate ventilation of toilets, either natural or mechanical, is necessary. (d) Adequate supplies.-The necessary supplies for the toilet room should always be adequate. (e) Cleanliness and maintenance.-The toilet room should be free from scraps of paper and should be cleaned regularly. Floors and base wall should be constructed of a material impervious to moisture and the seat traps and all plumbing facilities should be properly maintained. (3) Washing facilities. (a) Adequate supplies.-From the standpoint of personal hygiene there should always be adequate washing facilities. It is essential that employees in many industries handling certain types of materials, or engaged in certain processes, carefully wash their hands before handling food. It is necessary, of course, that there be an adequate supply of hot and cold water and plenty of soap and towels. The common towel is condemned. Paper towels are probably the best, as they are discarded immediately after use. (b) Arrangement. The arrangement of washing facilities is important in relation to convenience of use and ease of cleaning. Conveniently arranged washing facilities encourage their use. If properly arranged, wash basins will be in a light, airy room that permits ease of cleaning and maintenance of good housekeeping. (c) Shower baths.-Certain types of processes require shower baths for the protection of the health of the workers. health of the workers. The shower baths and such accessories as false floors and mats should |