It’s Not “If” You Will Experience an OSHA Inspection, It’s “When”

Inspection Priorities

OSHA inspectors are referred to as “Compliance Safety and Health Officers” and are highly-trained industrial hygienists and safety experts. Their efforts support the reduction of workplace hazards, preventing employer, employee and customer injury, illness and death. They prioritize:

• Imminent Danger Situations – Working environments that include exposure to areas of direct hazards that could lead to death or serious physical harm.
• Severe injuries and illnesses – Employers are required to report all work-related fatalities within 8 hours. Work-related inpatient hospitalizations, amputations, or losses of an eye must be reported within 24 hours.
• Worker Complaints – Internal allegations made by employees and workers of hazards or violations receive high priority for OSHA as well.
• Referrals of Hazards From Other Agencies – Referrals from Federal, state or local agencies, individuals, organizations or the media receive consideration for inspection.
• Specifically Targeted Inspections – These inspections are aimed at high-hazard industries or individual workplaces that have experienced high rates of injuries and illnesses.
• Follow-Up Inspections – These follow-up inspections check for how employers have remedied violation situations where they were cited during previous inspections.

The Importance of Having a Plan

In an online article written in Safety and Health Magazine, senior consultant with the National Safety Council, JoAnn Dankert suggests that when OSHA comes to your business to conduct an inspection, establish in advance a procedure that you and your team will follow. She says, “Your plan should identify a person at your facility, such as the safety manager or the owner, who will be responsible for escorting the inspector. Select a meeting space for opening and closing conferences. An employee representative also will be allowed to attend these conferences and the walk-around.” She stresses the importance of also having a Plan B in place if your main safety contact is unavailable on the day of the inspection. Train this person in how to manage such procedures.

The Bottom Line

• Verify OSHA Inspector Identity – Request to see the inspector’s identification to ensure that he/she is in fact an OSHA officer. Official OSHA inspector ID’s include a photo, name and office. It will not be a badge. Write down the inspector’s name and office and if there is any doubt as to their legitimacy, call your local OSHA office.
• Be Professional – Says JoAnn Dankert, “They aren’t going to let you buy them lunch, but if you’re nice to them, they probably will be nice to you. If you’re adversarial toward them, they will probably take a hard stance.”
• Establish Procedures in Advance – Identify a person at your facility who will be responsible for escorting the inspector, meeting spaces for opening and closing conferences, an employee representative to attend conferences and walk-arounds, and establish a Plan B in case your primary safety contact is unavailable for the inspection.
• Determine the Scope of the Inspection – What will the inspection entail and what prompted it – employee complaint, injury, etc.
• Ensure the Safety of Inspector – Make sure that OSHA inspectors are dressed and outfitted properly for the potential hazards of your workplace.
• Have Records Easily Accessible – Operating from a place of organization and preparation will allow for a more smooth inspection process. Having key records easily accessible will aid in that process.
• Document the OSHA Inspection – Take ample notes, photos and video if possible to fully document the inspection process, not only to correct hazards that are pointed out, but also to protect your business by maintaining clear records.
• Provide a Space for Inspectors to Interview Employees – During the inspection, OSHA officers may want to interview employees on work conditions and their experiences, so providing a quiet, private space for interviews will be helpful to the process.
• Comply with OSHA Suggestions and Citations – Implement immediately what you learn from the OSHA inspection, remedying hazardous conditions and environments as soon as possible to avoid further citation.