Every year OSHA inspects tens of thousands of workplaces from coast to coast. And since you never know when they will arrive, it is best to have a plan of action in place.
Why would OSHA conduct an inspection?
- Somebody has made a complaint about worksite safety or health--perhaps a current or former employee, or perhaps even a resident from the community who is worried about hazardous materials or some other safety or health hazard that could affect the area surrounding your company.
- A fatality has occurred in your facility.
- It's a regularly scheduled inspection. This is most likely if you are in a high-hazard industry. Thousands of high-hazard worksites are targeted for unannounced, comprehensive safety and health inspections every year.
- It's a follow-up visit, perhaps to determine if prior violations have been corrected.
- What are inspectors looking for? Inspectors are looking for violations of OSHA standards.
8 Top Violations
The exact kind of violations depends on the nature of your operations and the particular hazards of your workplace. However, you and your employees should be aware that last year's list of the most-often-cited OSHA violations for general industry featured safety and health problems related to:
- Machine guarding
- Ladders and scaffolding
- Hazardous chemicals
- Respiratory protection
- Fall protection
- Electrical safety
- Powered industrial trucks
Inspections can cover pretty much your whole facility, or they can be limited to certain areas, operations, conditions, or practices. But remember, a limited inspection can always be expanded, depending on what inspectors find once they get inside.
How is the inspection conducted?
The agenda for OSHA inspections are generally pretty standard and include five basic steps:
When inspectors show up, the first thing they do is present their credentials to the facility manager. Although companies have the right to require a warrant at this point, most prefer not to take a confrontational stance and simply invite the inspectors to enter the facility.
During a brief opening conference with members of management and employee representatives, compliance officers explain the nature and purpose of the inspection and indicate the scope of the inspection and the records they wish to review. If the inspection was triggered by an employee complaint, the inspectors will provide a copy of the complaint, but not the employee's name.
The inspectors will then ask to examine the OSHA 300 Log and other accident and illness reports. They might also ask to see such things as a copy of your hazard communication program, lockout/tagout procedures, or fire safety programs. They'll also check to make sure that OSHA safety and health posters are appropriately displayed.
During the walk through inspection, inspectors will look for violations of specific OSHA regulations. They will probably want to talk to employees and supervisors--and they have that right. Employees also have the right to talk to OSHA inspectors. They can even talk to them privately if they want to.
The inspection wraps up with a closing conference during which the inspectors review any violations and discuss possible methods and timetables for correction. Inspectors will describe the company's rights and responsibilities and answer any questions at this time. They'll also explain that violations could result in a citation and fines.
OSHA Inspection Toolbox
Another part of preparing for an OSHA inspection is to put together a last-minute Inspection Toolbox that contains some necessary items in order to avoid a frantic search for these items.
- A still camera or a video camera should be used to take pictures or recordings of things that the inspector has pointed out as possible violations or issues of concern as well as to take duplicate pictures of things that the OSHA inspector photographs.
- Clipboards, notepads, and plenty of pens.
- Flashlights to help look in those hard-to-see areas.
- Extra PPE for both the inspector and your key people. Demonstrate your dedication to safety by wearing, and making the inspector wear, PPE when it is required.
- A current facility map that will help the inspector get a feel for your facility and understand how your operations are set up.
- Location of key safety documents. Include a list of safety documents as well as a key for opening a filing cabinet, if necessary.
- Location of chemical exposure monitoring equipment as well as keys to storage areas or cabinets that contain the monitoring equipment.
- Always be truthful when dealing with the OSHA inspector. Lying to an OSHA inspector can lead to a $10,000 fine and a year in jail.
Stuart Nakutin is the Director of Loss Control Services & Claims for Cavignac & Associates. www.cavignac.com.