OSHA Inspection Procedures

While the majority of companies are trying to keep their employees safe, a visit from an OSHA inspector can still be a stressful experience. The Occupational Safety and Health (OSH) Act of 1970 grants representatives of the Department of Labor the right to inspect any place of employment in order to determine whether an employer is in compliance with the Act’s safety and health standards. Compliance inspections are initiated and prioritized based upon the following criteria:

  1. Imminent danger situations – hazards that could cause death or serious physical harm receive top priority.
  2. Severe injuries and illnesses – employers must report:
    • All work-related fatalities within 8 hours.
    • All work-related inpatient hospitalizations, amputations, or losses of an eye within 24 hours.
  3. Worker Complaints – allegations of hazards or violations also receive a high priority. Employees may request anonymity when they file complaints.
  4. Referrals of hazards from other federal, state or local agencies, individuals, organizations or the media receive consideration for inspection.
  5. Targeted inspections – inspections aimed at specific high-hazard industries or individual workplaces that have experienced high rates of injuries and illnesses also receive priority.
  6. Follow-up inspections – checks for abatement of violations cited during previous inspections are also conducted by the agency in certain circumstances.


Should this event happen to you, there are series of steps to take to try and make the inspection go as smoothly as possible.


Upon Arrival of the Compliance Officer (CO)
Ask to see his/her credentials which include both a photograph and a serial number. Then politely, let the CO know you’ll need to contact company management as well as your safety representative {which may include your safety consultant}. The OSHA CO will typically wait about 30 – 60 minutes for a representative to get to the site.


Opening Conference
The CO will have what’s known as an opening conference. During this conference, you will look to ascertain the reason and the scope for the visit – basically, why they are there and what they’re looking for. At this point, you should also determine your logistics for the inspection process.


Walkaround Inspection
If the CO does perform a physical inspection of your facility/site: (1) ensure they are always accompanied by a member(s) of your safety/management team, (2) only take the CO to the location(s) determined from the Opening Conference, and (3) DO NOT admit that something is a violation or discuss your knowledge of a violation situation – which can allude to a “willful” citation.
Take copious notes of the entire inspection, including taking photographs of everything the CO documents.
You can also expect that the CO will consult privately with a reasonable number of employees during the inspection – again, identified in the Opening Conference.
If any documentation (e.g. OSHA logs, safety programs, training records, etc.) is requested, ask that a formal document request to be put together – this helps to ensure there is no confusion and you get the CO exactly what they are asking for.


The Closing Conference
After the Walkaround, the inspector is required to have a closing conference with the employer and employee representatives. At this point, OSHA will discuss “apparent violations”. This is your last chance (prior to the citation being issued) to clarify any misunderstandings.
As this can be all be stressful, simply ensure that you have a plan in place to make sure the inspection goes as smooth as
possible.

For questions and/or more information about this brief, contact your Vista Safety Representative:

Roger M. Paveza, CRIS President
847.951.7544 roger@vistasafetyconsulting.com

Kyle Cochran, CSP Sr. Vice President
812.201.7150 kyle@vistasafetyconsulting.com

Eric A. White, CHST, CRIS Sr. Vice President
708.560.6244 eric@vistasafetyconsulting.com

Muhummad Starks Safety Consultant
720.937.5087 mstarks@vistasafetyconsulting.com

Any information and/or recommendations contained herein have been compiled from sources believed to be reliable and represent the best current opinion on the subject. No warranty, guarantee, or representation is made by Vista Safety Consulting, LLC as to the absolute correctness or sufficiency of any information contained herein. This information is advisory and designed to assist clients with the implementation, management, and control of their own safety program and activities. Vista Safety Consulting, LLC assumes no responsibility for the implementation, correction, or control of any conditions or recommendations identified herein, and is thereby not liable for any health and safety violation(s) and/or injuries on a site.

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