If OSHA shows up tomorrow are you prepared? Most companies are not prepared – follow this practical guide for a much smoother visit. 

When the inspector arrives:

Alert designated point of contact: (identify key individuals to be on alert – Typically HR Manager has the face-to-face initial contact – alert the GM, key Production Manager/Director, and possibly the Controller)

Ask to see the inspector’s credentials and verify them by calling your local OSHA office.

Ask the inspector what the scope of the visit is regarding and only take them to the specific area/equipment they are here to address/inspect.

DON’T: Be afraid to ask OSHA to wait if your designated point of contact is off-site.

  • Let the team know of visit (they can perform a quick audit/walk through while the opening conference is going on to make sure everyone is wearing their required PPE and areas are cleaned-up).OSHA Inspector

Opening Conference:

DO: Ask to see any written complaints that prompted the inspection.

DO: Confirm and, if necessary, negotiate the scope of the inspection.

  • Plain view doctrine- we can be fined for anything seen as a hazard while traveling to point/area of interest. (EX:  Should we walk them outside of building instead of through to get to area of concern?)

DO: Require the inspector to follow all workplace safety procedures (hearing protection, safety glasses, etc.).

DO: Identify areas of the workplace that might reveal trade secrets and confirm that

photographs will be marked “Confidential.”

DON’T: Don’t be a volunteer.  Answer only the question asked.

DO: Have all written policies and procedures organized and ready to review at all times

DO: Have OSHA Logs for the last 4 years available and ready to view at all times

NOTE:  Copies of all final year OSHA logs are located in __________________ office marked “Safety”.  Osha will only ask for the last 4 years.  In same drawer should be files of any testing (air/noise) conducted.  Current year log is kept up to date and is in ________________ (See HR for printed report)

Safety Programs and Polices are found in a binder in _____________.  SDS sheets are also stored electronically _______________ under _______________.

All safety concerns/action items maintenance requests are located in _______________.

Inspection/Walkaround:

DO: Allow inspectors to take pictures, measurements, or samples (paying attention to trade secrets).

DO: Mirror the OSHA inspector’s investigation.

DO: Remember the scope of the investigation and direct the inspectors only to the area they are addressing.

DO: Immediately correct (abate) unsafe conditions observed during the inspection, if possible and make sure the inspector is aware the condition was corrected.  Photograph before/after.

Mirror the OSHA officer’s inspection:

  • Take the same Photos
  • Take the same Measurements
  • Evaluate and make notes of Industrial hygiene measurements taken (I.E., noise levels in a specific area)

Taking notes

Take Notes:

  • Comments made by OSHA officers
  • Employee interactions
  • Requests for records

Interviews:

DO: Prepare management employees, if possible.

DO: Know that OSHA may interview hourly employees (10% of workforce) in private.

DO: Ask to participate in any management employee interviews and take good notes.

Document Requests:

DO: Ask OSHA to put requests in writing.

DON’T: Demand a subpoena.

DO: Make sure that records produced are complete and accurate.

DO: Keep a list and copy of all documents produced.

Closing Conference:

DON’T: Admit to violations or recognize alleged hazards.

DON’T: Attempt to argue or settle citations with the inspector during the conference.

DO: Take good notes during the conference.

DO: Ask questions about the specific standards being cited and citation classifications.

If you need help with OSHA compliance and preparing for the inevitable OSHA visit, call Three Sixty Safety at 586-778-9900 to learn more about how we can help prepare your company.