Nevada's Occupational Safety and Health Administration (Nevada OSHA) is performing targeted inspections of Nevada's hospitality establishments. Even though Nevada OSHA's "Inspection Targeting Plan and Emphasis Programs" document was last updated in August 2021, the programmed inspections are continuing with local emphasis programs related to hotels (NAICS 721110) and casino-hotels (NAICS 721120).
Hospitality establishments may want to prepare for potential on-site Nevada OSHA inspections. The Nevada OSHA inspections have thus far generally focused on ensuring that establishments have instituted compliant safety policies and trained all employees on the following:
- A written safety program.
- A written bloodborne pathogen exposure control plan (ECP).
- A written hazard communication program.
- A complete chemical inventory for an establishment's location, including an inventory list and corresponding safety data sheets.
- An emergency action plan.
- A COVID-19 ECP.
Documentation establishing that employees have been trained on each of the above (if applicable to an employee's job duties) may be requested by Nevada OSHA.
Additionally, during the inspection process, Nevada OSHA has recently been requesting hepatitis B vaccination declination or acceptance forms for employees covered under section 604.01 of the bloodborne pathogen ECP regulations.
Nevada OSHA may also demand required safety program documents, such as OSHA 300 injury and illness logs and 300A certified summaries for the past three years and sharps injury logs for the past three years.
As part of their preparations for potential Nevada OSHA visits, hospitality employers may want to revise applicable policies and circulate them. Employers may also wish to retrain their employees on the applicable policies (and document the same) and educate supervisors and managers on proper Nevada OSHA inspection protocol.
Karen F. Tynan is an attorney with Ogletree Deakins in Sacramento, Calif. Noel M. Hicks is an attorney with Ogletree Deakins in Las Vegas. © 2021 Ogletree Deakins. All rights reserved. Reposted with permission.