Confidential Location


To assist a pharmaceutical manufacturer prepare for its OSHA Voluntary Protection Program inspection, HRP was retained to complete an OSHA Compliance audit. Specifically, HRP reviewed the facility and compliance related documentation for compliance with the following OSHA topics:


OSHA General Industry Standard

Confined Space

29 CFR 1910.146

Materials Handling (Lifting Weights)

General Duty

Powered Industrial Trucks (Forklifts)

29 CFR 1910.176

Personal Protective Equipment (PPE)

29 CFR 1910.132-139


29 CFR 1910.147

Exit/Egress (Proper maintenance of)

29 CFR 1910.35-38

Industrial Hygiene and Air Contaminants

29 CFR 1910.94, 29 CFR 1910.1000-1052

Hazard Communication

29 CFR 1910.1200

Machine Guarding*

29 CFR 1910.211-219


29 CFR 1910.179-184

Noise Exposure/Protection

29 CFR 1910.95

Walking & Working Surfaces

29 CFR 1910.21-30

Hazardous Materials

29 CFR Subpart H


29 CFR 1910.251-255

First Aid/Bloodborne Pathogens

29 CFR 1910.151, 29 CFR 1910.1030

Flammable Liquids

29 CFR 1910.106

Emergency Action Plans/Fire Prevention Plans

29 CFR 1910.38

Electrical Safety*

29 CFR 1910 Subpart S

Fire Protection

29 CFR Subpart L

Welding and Brazing

29 CFR Subpart Q

General Safety (Observation of unsafe acts or conditions)

General Duty

To complete audit, HRP conducted:

  • A two day site walkthrough;
  • Interviewed representative facility personnel; and
  • Reviewed provided safety related Health, Safety, Environmental & Business Continuity Procedures, OSHA compliance plans, training records, and industrial hygiene reports. 

The information collected was utilized to evaluate if manufacturing operations are consistent with respect to the OSHA regulations contained in 29 CFR 1910 and general safety practices. The remainder of HRP’s letter-report summarized our findings and recommendations.  Also, tables specifically outlining deficiencies and other “non violation” findings that may be potential safety concerns, as well as, recommended actions are included at the end of our letter-report. The report specifically included recommendations for facility modifications or operational/work practice changes recommended to ensure consistency with existing and/or proposed regulations. Lastly, HRP assisted in the prioritization of the corrective actions to ensure that the pharmaceutical manufacturer was prepared for this VPP inspection.

OSHA has recommended the company for VPP Star status and  acknowledged the company's risk portfolio methodology and business continuity planning to be Areas of Excellence.