I spent today inspecting a small Mom-And-Pop type of business. The business was very small and owned and run by someone that was a spitting image of Santa Claus.
How could I possibly think of finding violations to give this jolly owner a citation?
It got me to thinking…if I had to inspect Jolly Santa himself, what would I find? I suppose I could find Santa in violation of a few safety standards. This is what I would think:
1. §T8CCR 3202 Injury Illness Prevention Program
An Injury Illness Prevention Program was not written and implemented that includes all the elements of this standard such as: Designating who is in charge of safety; Conducting work place self-inspections; Training of elves; Having procedures in place to correct workplace hazards; Having an effective way of having elves report hazards; and Procedures to investigate accidents. No, his so-called "LIST" will not meet the requirements.
2.§T8CCR 5097 Hearing Conservation Program
A Hearing Conservation Program was not developed for the Elves and Santa himself when exposed to the wailing and screaming of snotty nosed ankle biters who when sitting on Santa’s lap undoubtedly expose Santa and his elves to an excess of 110 decibels.
It was noted that hearing protection was not worn by either Santa or the elves.
3. §T8CCR 5199 Aerosol Transmissible Diseases An Aerosol Transmissible Diseases Exposure Control Plan was not developed to protect Santa himself and the elves from the same ankle biters as mentioned above. The snot-nosed disease carrying diaper soilers are exposing Santa and the elves to countless identified and yet to be discovered diseases that are in all likelihood capable of making Santa and the elves ill, if not having effects of depression, altered states of consciousness, hallucinations of grandeur and suicidal tendencies.
4.§T8CCR 5199.1 Aerosol Transmissible Diseases-Zoonotic
An Aerosol Transmissible Diseases Exposure Control Plan (zoonitc) was not developed to protect Santa himself and the elves from the transmissible diseases generated by the reindeer. This is especially vital for Santa when he spends hours sitting directly behind and in close proximity to the reindeer’s butt-holes on Christmas Eve while delivering gifts. No protection, or means to avoid gaseous releases or flying crap emanating from said reindeer is provided.
5. §T8CCR 5157 Permit Required Confined Spaces
Santa has not identified the permit required spaces (chimneys) and labeled them as such. Further more, he does not test the air to determine that entering the confined space does not contain a toxic atmosphere, explosive atmosphere, or oxygen deficiency. No rescue operations, and “Man on Top” has been provided in the case the jolly fat man becomes wedged in the chimney and cannot come out on his own accord.
6. §T8CCR 5144 Respiratory Protection
It has been determined that Santa is often exposed to soot and smoke in excess of Permissible Levels. Regardless of the fact that he might fry like a butterball turkey as he descends the chimney when a log fire is raging, he should have respiratory protection as he enters the smoke pit.
As a side note, please be aware that in order to comply with this standard, the wearer of a respirator must be clean shaven.
7. §T8CCR 3308 Hot Pipes and Surfaces
In reference to the afore mentioned fireplace fire, the interior of the chimney where Santa is exposed to, must be have thermal insulation or other means to protect him from caramelizing his personal surface and to protect him from becoming crackling.
8. §T8CCR 3395 Heat Illness Prevention Program
It has been determined that Santa is exposed to temperatures above 90 degrees F while descending hot chimneys. This temperature is enough to make this standard enforceable. All the elements such as provision of water, heat stress training, procedures for acclimatization, procedures to call for medical aid (simply calling 9-1-1 is NOT enough) and shade is required.
9. §T8CCR 3273 Working Area
Roof tops are not free from slippery hazards since they are often covered with snow and ice. Santa must insist that owners of the facilities he is to visit provides him with a safe working area if he is to bring their greedy little worm eaters the presents they demand. Owners of the rooftops will be considered the exposing, and creating employer in this dual employer relationship and can be likewise cited.
10. §T8CCR 3210 Elevated Locations
Landing on peaked rooftops with animals with cloven hooves and a sleigh filled to the brim with heavy items, not to mention a heavy person is hazardous. Fall protection of some sort must be provided. A guard rail can be installed or safety harnesses can be used by all who land on the roof. The fact that the animals can fly to safety should they slip does not provide an exemption from this regulation, furthermore, as it is obvious that the red-suited jolly guy cannot fly, and no matter how much snow is on the ground, it would not provided ample cushioning to soften his fall.
11. §T8CCR 3215 Means of Egress
Since Santa often plummets himself down into a raging fire, a safe means of egress must be provided. To expect him to go back into a fireplace with logs ablazing is not only hazardous, but potentially life threatening. Exit routes must be clearly marked, and the doors shall be unlocked during business/delivery hours.
12. §T8CCR 3217 Decorative Materials
Decorative materials such as Christmas trees, Stockings-Hung-By-The Chimney-With-Care and sugar plums shall not constitute a hazard. Nor shall they be located close to the fireplace in the event that Santa’s buttocks become enflamed from the fire of the fireplace and thereby cause a great fire by having the said decorative items too close to the source of the fire.
It regrets me to say, that with all these violations of Cal/OSHA, most of which are Serious violations, carrying a significant financial penalty, not to mention the grave dangers these violations would present, that Santa will be served with an OPU (Order to Prohibit Use). He has 15 days to appeal the citations and prepare a statement as to why he should not be cited. During preliminary discussions with the safety violator, he appears only too happy to have the season off.