Following a near miss incident in a wood products manufacturing operation, an OSHA inspection resulted in requirements for several process changes. The changes were strictly based on perceived non-compliance with OSHA standards. The requested changes created substantial difficulties for the manufacturer due to the tightly integrated nature of the operation. To implement the OSHA changes would have created substantial problems for the manufacturer in terms of reorienting work flow, modifying equipment, and lost operations to make the changes.
As an alternate to the compliance assessment conducted by OSHA, the risk assessment process was used to better understand the particular hazards and evaluate options to reduce risks to an acceptable level. The risk assessment demonstrated that certain process changes OSHA required would increase overall risk, e.g., although egress risks would decrease, the ergonomic risks would greatly increase. The risk assessment also helped to identify alternate risk reduction methods that could be reasonably implemented by the company that addressed the underlying concerns raised by OSHA. In this instance, the risk assessment process moved the discussion from a compliance/non-compliance argument to a discourse on how to reduce the risks of particular hazards to an acceptable level for all parties. The risk assessment process was successful in this regard.