GREAT points.
OSHA is absolutely black and white. The General duty clause says (paraphrased) YOU WILL KEEP YOUR EMPLOYEES SAFE WHILE DOING WORK.
For them, it someone gets hurt, they will come to make sure you were doing enough. (Criteria not discussed here).. You see, when they come out, you MUST let them in. (I hope everyone knows that) , Then they will hold a briefing with your safety/supervisory staff, Give you a list of documentation they want to see. Then go to look at the site of injury, then interview your witnesses --- ALONE. YOU will not be able to hear what your staff has to say. If your staff has a grudge or misstates something, you )leadership) will not be able to defend or correct. They then review the documentation you have of training, written procedures/protocols, records of other injures and accident prevention. They then leave, and they have up to 6 months to do the citation, during which they are consulting with their supervisions and the gov for possible criminal prosecution. if the write the citation, one it comes to you, you have 2 weeks to fight it or pay it (which generally takes lawyers of you fight) either way, it costs alot of money that no one here has!
Remember that I on only taking about the law and OSHA's position. What I did for all those years, was translate the lawyer speak that OSHA law is written in, into terms that everyday people or people who spoke English as a second language, could understand.
At the beginning of every class, I would start by explaining this example.
Picture a BIKE.
Now for years this is how it would turn out. 3/4 of the students wold picture a bicycle, slightly lese then 1/3 would see a motorcycle. I would generally have an odd one that would pick a tricycle, I as the instructor would pick something different like a exercise bike.
I would say - ok who is right? Bicycles (workers)? Motorcycles (Supervisors) or how about the exercise bike (your instructor who decides if you pass or not <vbg>, or the business who pays you?
So you can see that the more you standardize, document, train, and record, the more ammo you have to show OSHA you did everything possible. You want them to leave your building FEELING you did everything possible.
All they care about, is the safety of the employee and no matter what we talk about they had been be safe. OSHA wants to see engineering, administration, and more controls
So referring to a bite, start with the hand stick, WEARING bit gloves, then handle the dog with bite gloves and pants with other protocols. I agree a bite stick doesn't do anything EXCEPT as a first step to showing a dog doesn't bite, then the supervisor/trainer periodically checks that the employee (volunteer) is keeping face away from dog, and other safety procedure and protocols.. Signs the inspection form and files it away.
To answer your third paragraph, you have to be able to show that the dog is not a risk. OSHA would argue, all dogs can bite, all cats can scratch, how do you protect your employee from that, period.
One thing we could do as an industry, can do, is to adopt standardized safe protocols and practices like the agency ANSI does. they set standards that OSHA recognizes and in fact even refers to them in the law. Like safety gasses, standards fill a quarter inch 8.5x11 . Rather then quoting what ANSI says OSHA says by reference ANSI Z-87... So basically OSHA says, if it meets ANSI standards, it is good enough for OSHA! https://www.ansi.org/
Hope this clarifies.
So that is what I did
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