/ FACTORY INSPECTION STANDARDS AND QUALIFICATIONS FOR FACTORY INSPECTORS PREPARED BY ADVISORY COMMITTEE ON SAFETY AND HEALTH UsTdepositorv 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. II 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 1 ^ 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 3 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. Applicant must possess the following qualifications: Citizenship. Experience. Education. Age. 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 employe'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 employments. 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 6 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 Physical sound physical health, as considerable physical and c l uallflca ' lon$ - 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 Written required to take a written examination aimed to examma,| o n ' 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 Oral eligible grade on preliminary ratings shall be re- exammarion - 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 Basis of rated on the extent and quality of their experience, rat,n 3- education, and fitness that are relevant to the duties on a scale of 100, such rating being based upon 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 8 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, 9 UNIVERSITY OF FLORIDA 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. 10 U. I. GOVERNMENT PRINTING OFFICE: 1931