Wednesday, July 8, 2009

Evaluations - Lapse Time

I got this comment on CSHO evaluations I want to follow-up:
"I do not understood this bizzare obsession with 'lapse time.' I'm not sure exactly what lapse time indicates. It's been said that low lapse time indicates quick abatement. This assumes that most employers do not act in good faith to correct a violation as soon as the CSHO brings it to their attention. Typically this is the exception to the rule. In my experience most employers begin trying to fix things as soon as they're brought to their attention by a compliance officer.

The ironic thing with lapse time is that inspections involving those bad actors who can be counted on not to abate a violation until absolutely forced to are the source of most significant cases. These cases intrinsically have the longest lapse time, most approaching the full six months, due to regional and national office review of the cases.

The whole lapse time thing just seems like a red herring. And it does encourage some, especially hygienists, to take short cuts. Sampling takes at least three weeks to receive results. Don't sample and you can shorten your lapse time. I'd bet that offices with average lapse times under 15 days never do air monitoring.

The other thing that significantly increases lapse time is waiting on a process likely to cause overexposures to be active, such as an employer that sandblasts once a month or runs a process with chromium paints once a quarter. Most IHs now simply document 'process not active' in their case file, throw out some safety or haz com violations, and move on to the next inspection. Keeps their lapse time low. I don't think this is doing much to protect the health of potentially exposed employees."
I agree with much of what the commenter said, although I do object to the statement "Most IHs now simply document 'process not active' in their case file, throw out some safety or haz com violations, and move on to the next inspection." I don't do that and most of the IHs I know don't do it either.

I think there are two reasons we're obsessed with lapse time, it's objective and measurable, and employers hate having the ax hanging over their head, just waiting for the citations to show up.

How many measurable elements do we have in our evaluations any more? There was a time when we got extra credit for presentations and outreach type things, but the CAS positions have taken most of that away. We're not supposed to be evaluated on the number of inspections we do. So what's left? Violations per inspection? That doesn't make sense because then we would be on what would amount to a quota system, which brings into question our objectivity during an inspection and isn't fair to employers. What objective measures are left?

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