Is Cal-OSHA guilty of entrapment?

In the article about free gifts from insurance companies, we explored how you need to be really careful about what “free” safety plans you implement at your organization.  But the last place that you would think you would get a stinker of a plan would be the governmental body that gives it to you.  Several of the grey bearded safety professionals have commented on the notion that they believe Cal-OSHA may be setting themselves up to rake in the cash during inspections thru acts similar to police entrapment.

Entrapment is when you are coaxed into committing an offense that you would not otherwise have committed except for the fact that someone urged you into doing it.  When seasoned professionals start referring to free Cal-OSHA templates in the same vein as police entrapment, you start to wonder.   And wonder I did, until the other day I woke from my wondrous dream to the phone’s urgent ring tone.  And there it was – a client crying for help because the inspector was writing them up for an IIPP that wasn’t good enough to meet the Title 8, Section 3203 standards.   The little voice on the other end of the phone said something I had heard before – “I downloaded the free IIPP template from the Cal-OSHA website and it’s not good enough.”

Every good safety and risk management professional knows that you shouldn’t just take a free template and slap your name on it.  And most of have sat in plenty of ASSE meetings and heard Cal-OSHA Consultation tell us that we needed to customize their templates.  But when you start to see citations, fines, penalties and reports that state that the template doesn’t even meet the minimum standards – you have to wonder, is that template a form of entrapment?  We will be curious to see how the case turns out based on this premise of entrapment, but one thing is for sure, if the arguments are heard, you can say goodbye to free templates.

We always recommend that anyone using free templates to customize them.  Even if you receive what is suppose to be a great template or one you paid for, you need to read it and verify it.  We also recommend that you hire a true professional that can assess your situation and write a plan specific to your organization.   Read more on other ways OSHA entraps agencies.


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