Factory inspection standards and qualifications for factory inspectors

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Factory inspection standards and qualifications for factory inspectors
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ii, 10 p. : ; 23 cm.
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United States -- Division of Labor Standards. -- Advisory Committee on Safety and Health
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Factory inspection -- Standards -- United States   ( lcsh )
Labor inspection -- Standards -- United States   ( lcsh )
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prepared by Advisory Committee on Safety and Health, Division of Labor Standards, U.S. Department of Labor.
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FACTORY INSPECTION STANDARDS
AND

QUALIFICATIONS FOR FACTORY

INSPECTORS





PREPARED BY
ADVISORY COMMITTEE ON
SAFETY AND HEALTH










DIVISION OF LABOR STANDARDS
U. S. DEPARTMENT OF LABOR
WASHINGTON



















ADVISORY COMMITTEE ON SAFETY AND HEALTH
DIVISION OF LABOR STANDARDS
UNITED STATES DEPARTMENT OF LABOR

Cyril Ainsworth,
American Standards Association.
W. H. Cameron,
National Safety Council.
John P. Frey,
American Federation of Labor.
Thomas P. Kearns,
Ohio Industrial Commission.
R. R. Sayers, M. D.,
U. S. Public Health Service.
Albert W. Whitney,
National Conservation Bureau.
W. H. Winans,
Union Carbide Company.
















FOREWORD
In helping the Division of Labor Standards develop an effective
program to promote industrial safety and health the Division's
Advisory Committee has emphasized the need for developing
better factory inspection technique and higher qualification stand-
ards for persons appointed to do this important work, together
with ample service protection for the well trained and competent
inspector.
The Division has already moved in the field of factory-inspector
training and has aided interested States in establishing effective
methods for increasing the technical knowledge of the safety
inspector. Under this training plan, as carried out in a number
of States, factory inspectors have acquired the status of genuine
experts in the detection, control, or elimination of dangerous
hazards to the life and health of workers.
Following through with the next step, the Division is glad to
present in this pamphlet the specific recommendations of the
Advisory Committee on Safety and Health on desirable qualifica-
tions of a factory inspector and as to a merit system of selection.
Coming from a wholly nonpartisan group whose members are
nationally known experts in the field of safety and health, these
suggested standards deserve the close attention of legislators,
administrators, and executives in all jurisdictions.
It should be pointed out that these recommendations deal
entirely with the qualifications needed for that part of the work of
factory inspection relating to safe and healthful conditions. When
these duties are combined with other administrative functions
such as wage, hour, and child-labor regulation, it doubtless will
be necessary to extend these suggested requirements to assure full
competency.
VERNE A. ZIMMER, Director,
Division of Labor Standards.


122972-39



















Factory Inspection Standards and Qualifications
for Factory Inspectors


INDUSTRIAL SAFETY AND HEALTH TODAY
Under the stimulus and driving force of organized safety groups,
great strides have been made by industry in reducing injuries
and fatalities caused by work hazards. Except for this sustained
voluntary effort the annual toll in human life and physical im-
pairment, to say nothing of the monetary loss, would be tremen-
dously greater than it is today.
But the loss is still enormous, whether measured in terms of
men or in money. This is attested by the annual harvest of more
than 19,000 deaths and 1,600,000 disabling injuries, 75,000 of
the latter being permanently crippling. The direct money cost
of this yearly toll is about $700,000,000, and indirectly aggregates
a much higher sum.
The reason for this annual loss, now more or less constant, is
primarily because smaller industrial establishments have not
kept pace with the larger enterprises in respect of organized
safety effort. The significance of this is obvious when it is remem-
bered that 92 percent of the manufacturing plants in this country
employ fewer than 100 persons. In many of these smaller estab-
lishments safety programs and the application of engineering
technique to accident and disease prevention are either neglected
or ineffectively carried on. The general acceptance of this situ-
ation is reflected in the past and present demand for action by
the State in establishing and enforcing specific regulatory provi-
sions looking to better protection of the worker against occupa-
tional hazards.

REGULATORY APPROACH TO INDUSTRIAL SAFETY
Existing State regulations, though varying greatly as to scope,
are commonly aimed to remove or control specific hazards which


j











experience has shown are a frequent cause of accidents and
injuries. Generally speaking, these code or statutory provisions
are less comprehensive and less exacting in their requirements
than the measures voluntarily applied by large industrial organi-
zations in carrying out accident-control programs. As a rule
these State regulations represent only the minimum standards
that can be expected to bring about a reasonable degree of pro-
tection. Even at their best, however, the value of these regula-
tions in saving life and limb depends almost wholly upon intelli-
gent interpretation and persistent application. The factory
inspector under the usual State administrative set-up performs
an essential part in giving effect to these statutory regulations.

THE STATUS OF FACTORY INSPECTORS
This committee believes that any present or future regulatory
approach to the industrial-accident problem will largely be
ineffectual unless the factory inspector is in fact an expert in the
detection of accident hazards and thoroughly conversant with
technical and practical methods of eliminating or controlling
them. The failure in many States to recognize the importance
of the work of a factory inspector, the prevailing lack of standards
in some States in respect to requisite qualification and experience,
and the widespread lack of protection against dismissal for per-
sonal and partisan reasons are factors that are at least partially
responsible for seeming impotency in further reducing the number
of industrial accident casualties.
Hence, the committee is of the opinion that the first outstanding
need in the field of industrial safety and health endeavor is a well
devised and widely applied system of selecting, training, and
retaining qualified inspection personnel. This will produce an
inspectorate capable not only of competently applying definite
legislative enactments on well-recognized hazards, but also able
to bring to the average small plant management the safety
methods and technique so effectively employed by the larger
organizations. To this end the committee recommends the intro-
duction in every State of a system of merit tests, a sound training
program, and a plan that will reasonably insure a tenure of service
for the competent inspector.











A COMPETITIVE MERIT TEST
The following examination was prepared as a result of two
years of review and study by the Advisory Committee on Safety
and Health and is designed to bring into the service men with an
adequate and predetermined degree of technical knowledge gained
primarily through practical experience, men willing to absorb
additional information and able to impart this knowledge to
others with tact, diplomacy, and intelligence. In those States
having civil-service laws the use of this examination, under civil-
service procedure, is recommended. In other States the com-
mittee recommends that the examination be administered by an
impartial, nonpartisan board, which shall include representatives
of workers, representatives of employers, representatives from the
technical professions, and representatives of government admin-
istration, as an open competitive test, and that vacancies be filled
in the order of fitness as evidenced by the grade acquired.

QUALIFICATIONS FOR FACTORY INSPECTORS
Duties.-The duties are, under general super- Duties.
vision, to make inspections of places of employ-
ment with respect to compliance with the provisions
of the State labor laws and industrial codes, rules,
and regulations dealing with safety and health;
prepare accurate, detailed reports of inspections;
and, when necessary, obtain evidence of violations
and appear in court to testify at prosecutions.
Under supervision, to promote the active interest of
employers and workers in the establishment of
safety and health programs planned to provide safe
and healthful working conditions, and the establish-
ment of safe working practices; to act as consultant
and adviser on matters of industrial safety and
health to industry and to address employers' and
workers' organizations; to conduct accident in-
vestigations, interview witnesses, prepare accurate
reports of investigations, and make recommenda-
tions for preventing the occurrence of accidents and
occupational disease.












Citizenship.
Experience.





















Education.
















Age.


Applicant must possess the following qualifications:
I. He must be a citizen of the United States.
II. Experience.-Applicant must have had: At
least six years of satisfactory experience in factories
or mercantile establishments, of which at least three
years shall consist of work either as-(a) a journey-
man in one or more trades in a manufacturing
plant; (b) a foreman in a manufacturing plant; (c)
member of employee's committee or safety commit-
tee; (d) a full-time safety inspector in a manufac-
turing plant or its equivalent in part-time safety
work; (e) a satisfactory equivalent combination of
the foregoing employment. The practical shop
experience shall have been such as to permit oppor-
tunity to acquire a knowledge of fundamental
mechanics as applied to various operations, and a
knowledge of general shop practices and working
conditions.
At least three years of the required experience
must have been secured within the seven years im-
mediately preceding the date of closing and receipt
of applications.
III. Education.-Formal education in school or
college is not the prime test of qualification, for if
there is natural intelligence, ambition, and energy,
early educational disadvantages may have been
overcome. The test of formal education need not
go further than to establish the applicant's ability
to readily express himself, orally and in writing, in
a clear, logical, and convincing manner.
Completion of at least four years in such technical
courses as mechanical, electrical, civil, chemical, or
industrial engineering will be considered as equiva-
lent to four years' experience, provided the appli-
cant has had at last two years of practical experi-
ence in work enumerated in (a), (b), (c), (d), or (e)
in paragraph II above.
IV. Age.-The applicant shall have passed his
twenty-fifth birthday and shall not have passed his


I











fifty-fifth birthday. These limits may be waived
if, in the judgment of the examining board, the
applicant demonstrates sufficient maturity to per-
mit of and assure necessary experience and train-
ing, and if a reasonable period of effective service
can be expected.
V. Physical qualifications.-Applicant must be in
sound physical health, as considerable physical and
mental vigor is needed for the work of factory in-
spection, and must be able to establish by physi-
cian's certificate or physical examination that he is
in satisfactory physical and mental condition to per-
form the work required.
VI. Written examination.-Each applicant shall be
required to take a written examination aimed to
show, in addition to the technical knowledge re-
quired for factory inspection work:
(a) Ability to express himself clearly and effec-
tively in writing.
(b) Ability to apply his knowledge to specific
problems pertinent to the work.
(c) Practical knowledge of accident prevention
and industrial health conservation methods.
VII. Oral examination.-Applicants obtaining an
eligible grade on preliminary ratings shall be re-
quired to report for an oral examination. The pur-
pose of the oral examination is to substantiate the
evidence already secured regarding the extent and
character of the applicant's experience on which
the preliminary ratings were based; to further
evaluate the factors of leadership, tact, resourceful-
ness, discretion, intelligence, ability to express him-
self clearly and effectively, degree of emotional
stability, and applicant's concept of the relation-
ship between government and industry.
VIII. Basis of rating.-All applicants shall be
rated on the extent and quality of their experience,
education, and fitness that are relevant to the duties
on a scale of 100, such rating being based upon


Physical
qualifications.






Written
examination.









Oral
examination.












Basis of
rating.











applicant's sworn statement and upon corrobo-
rative evidence.
WEIGHTS
1. Experience and Fitness................ 70
2. Written Examination................. 30
Total ................... ........ 100
The oral examination shall be given in the order
of the applicants' standings as a result of the pre-
liminary rating; and such preliminary ratings may
be adjusted in accordance with the results of the
oral examination.

TRAINING
Hand in hand with proper selection, a one-year probationary
period of training and experience for the newly appointed
inspector is recommended, with a final qualifying examination
by the board administering the merit system before permanent
appointment. This training should be conducted, first, in the
main headquarters of the department so that the employee can
be thoroughly grounded in the basic knowledge of the laws he
will be called upon to enforce, the special history and traditions
that have been built up through the enforcement of these laws
over a period years, and can acquire a thorough understanding
of the paper work required.
Following the course at headquarters, inspectors should be
taken out into the field by a specially qualified inspector for a trip
to certain prescribed plants where arrangements have been
made in advance for a study of the ways in which specific laws,
rules, and regulations have been applied to conditions in such
establishments. The inspector in this way learns the method of
entering a plant, the approach which he should make to the
plant manager, and the routine procedure of making arrange-
ments for a proper plant inspection.
After a sufficient period of time spent with the experienced,
qualified inspector, the new inspector should be assigned to an
inspection district where his work will be carried on under direct
supervision through the medium of a supervising inspector in










charge of the district, or directly under the supervision of the
headquarters staff.
The committee recommends at least one week's training de-
voted to the routine studies at headquarters, not less than one
week with the headquarters inspector visiting industrial plants for
observation purposes, and not less than two weeks with a regular
field inspector or with a district factory supervisor. Arrange-
ments should be made if possible to have new inspectors enroll in
one of the cooperative training courses in the fundamentals of
safety and health of the type jointly sponsored by a State or group
of States in cooperation with a college or university and the Divi-
sion of Labor Standards of the United States Department of
Labor.
At the end of the probationary period there should be not only a
record of the inspector's understanding of safety and health laws
and practices but also evidence of tact, zeal, ability, initiative,
interest in the work as a whole, and willingness to assume re-
sponsibility. Upon such record should be based encouragement
through opportunities for promotion.

SECURITY OF TENURE OF OFFICE
Equally as important as appointment and training is a reason-
able assurance of permanence of office for competent inspectors.
Administrative experience is not only a valuable public asset,
which should be conserved, but, moreover, insecurity in office for
nonservice reasons tends to demoralize law enforcement. It is,
therefore, urgent that the system give qualified inspectors the
protection of civil-service tenure or its merit-rating equivalent.
The adoption of a competitive merit system in the selection of in-
spectors and a sound training program will go far in creating a
public consciousness which will not tolerate arbitrary dismissal of
qualified inspectors.
CONCLUSIONS
It is the hope of the Advisory Committee on Safety and Health
that the suggested factory inspection standards and qualifications
for factory inspectors outlined herein will be widely adopted and
provide the much-needed improvement in the selection, training,




UNIVERSITY OF FLORIDA
H lIIl I H I I I I H1111I II I I11111111111
3 1262 08860 0233


and security of factory-inspection personnel. While many of the
States have made substantial progress in developing adequate
safety and health regulations, comparatively few have made an
equal advance in the technique of compliance. The committee
realizes the fundamental part which must be played by factory
inspectors in this tremendous organized war against industrial
accidents and occupational diseases. Through the adoption of
this program the Advisory Committee visualizes a factory in-
spector who commands the respect of industry and invites the
confidence of workers because of his knowledge, integrity, and
ability to bring about a greater degree of health, safety, and
comfort.


U.S. GOVERNMENT PRINTING OFFICE:Z 1I3




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