Preparing for an OSHA Inspection

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Company safety managers should know how to prepare for OSHA inspectionsThe Department of Labor’s Occupational Health and Safety Administration (OSHA) oversees the health and safety of more than 130 million American workers and employs some 2,100 inspectors to ensure that workplaces comply with federal health and safety guidelines.

“OSHA’s efforts – rulemaking, enforcement, compliance assistance, and training – are tools to accomplish our mission of safety and health for every worker,” Principal Deputy Assistant Secretary of Labor for Occupational Safety and Health Loren Sweatt, said in a December 2019 OSHA press release issued.

OSHA compliance officers may show up at a workplace for a variety of reasons, according to EHS Today. While the chance of an unannounced visit from OSHA auditors is low, preparing for an OSHA inspection means safety managers must plan ahead alongside other managers and supervisors.

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What OSHA Looks for During an Inspection

OSHA inspectors are “well-trained industrial hygienists and safety professionals,” the agency noted. They typically show up without warning to conduct health and safety inspections for a number of reasons, according to EHS Today, such as:

  • Imminent danger
  • Fatalities and catastrophes
  • Severe injuries that require hospitalization, amputation or loss of an eye
  • Employee complaints
  • Referrals from law enforcement, other government agencies, or the media
  • Programmed inspections, such as National Emphasis Programs (NEP) or Local Emphasis Programs (LEP)

Before the on-site inspection, OSHA compliance officers review a company’s inspection history, operations and processes, and standards.

When the compliance officer arrives, safety managers are required to show the company’s credentials, including Federal Employer ID number, OSHA injury and illness logs, written programs, and training records, according to EHS Today.

Here’s what else companies should expect during an on-site OSHA inspection:

  • Opening conference. The OSHA officer will explain why the workplace was selected for inspection and the scope and procedures of the inspection.
  • After the initial conference, the officer and chosen employee representative(s) visit the parts of the workplace detailed in the inspection. OSHA is looking for violations or hazards that pose a threat to the workplace. The officer may ask employees questions about the workplace during the walkaround.
  • Closing conference. After the walkaround is complete, the compliance officer meets with the employer and employee representative(s) to review the inspection and discuss the findings.

If a violation is identified, the compliance officer issues a citation. Companies that receive OSHA citations can take these actions, according to EHS Today:

  • Acknowledge the citation, fix the problem, and pay the fine
  • Participate in an informal conference with OSHA
  • Send a written rebuke of the citation within 15 business days of the final order.

Safety professionals can request a copy of the complaint or complaints filed with OSHA, EHS Today noted.

How Safety Professionals Can Prepare

Because OSHA oversees more than 8 million workplaces throughout the country, the chances of an inspection, for many businesses, is low, according to a 2019 article, “What to expect when OSHA is Inspecting,” in Safety and Health Magazine.

Despite the slim chances, many experts recommend preparing for an OSHA inspection, the magazine reported. Documentation is a critical part of the process, Paul McNeill, a compliance safety and health officer with the agency from 2001 to 2013, told the magazine.

“The 11th Commandment with OSHA is, ‘If it’s not in writing, it never happened,’” McNeill said.

“Who greets the inspector, how the facility will correct small hazards, who’s in charge of gathering documents, and who will accompany the compliance officer(s) should all be part of an OSHA inspection preparation plan,” the magazine noted.

Slipnot, a non-slip flooring manufacturer, advised that workplaces could prepare for an OSHA inspection by taking these measures:

  • Maintaining proper documentation that ensures safety programs and training are in place
  • Keeping an injury and illness log that dates back at least three years
  • Keeping documentation of personal protective equipment hazard assessments for the preceding five years
  • Implementing an emergency action plan
  • Having a hazard communication program

Businesses also need to be prepared for what Slipnot called the “scary 13” – the records and documents that many employers fail or forget to provide during an inspection:

  • Lockout authorized employee training
  • A current list of chemicals used at the facility
  • Temporary employees’ OSHA 301 or state workers’ compensation report of injury
  • Training records for electrical safe work practices
  • Annual respirator training
  • Lockout/tagout audits
  • Personal protective equipment training
  • Noise exposure training
  • Bloodborne pathogens training
  • Confined spaces – non-permit certification
  • Forklift recertification
  • Written PPE hazard assessment with certification
  • Hazard communication training for all employees with current chemicals

Employee representatives, who should be chosen in advance, are expected to participate in the inspection, according to OSHA. If the facility is part of a union, the safety chair member from the union should represent the employees.

Companies may not look forward to OSHA inspections, but both employers and the federal agency ultimately have the same goals in mind: protecting personnel and ensuring safe workplaces.

“Employers are responsible for continuously protecting their employees from safety and health hazards,” OSHA Atlanta-East Area Director William Fulcher said in a 2018 press release. “OSHA offers compliance assistance resources and specialists that can help employers identify and correct hazards in their workplaces.”

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Recommended Reading

When Companies Refuse to Pay OSHA Fines

The Economic Aspect of Health and Safety

Occupational Safety in the Age of Robotics

SOURCES

Commonly Used Statistics: Occupational Safety and Health Administration

OSHA Enforcement and Compliance Increases in 2019 To Keep America’s Workforce Safe: Occupational Safety and Health Administration

How to Prepare for – and Manage – an OSHA Inspection: EHS Today

Occupational Safety and Health Administration (OSHA) Inspections: Occupational Safety and Health Administration

Ten Most-Asked Questions about the OSHA Inspection Process: EHS Today

What to expect when OSHA is inspecting: Safety and Health Magazine

Preparing for an OSHA Inspection: Slipnot

OSHA press release: OSHA