What To Expect When OSHA Visits (Part I)
Posted by Pauline Heidemann on Fri, Feb 10, 2012 @ 06:36 AM
An unexpected visit from OSHA may be intimidating, but the process can be less threatening if you know what to expect and how to handle the situation.
The reason you may find OSHA knocking on your door may be due to a random selection, a planned inspection, a local or national emphasis program, or an investigation following an accident, however, nearly half of all OSHA inspections are the result of an employee complaint, so there is a strong possibility OSHA has been assigned to investigate your facility for unsafe conditions or potential hazards. If the inspection is the result of a complaint, inspectors must limit their investigation to the items addressed in that complaint. Should an inspector wander into areas of your site not covered by the complaint, management has the right to escort the inspector away from the area.
The onsite visit begins with an opening conference, and continues with a review of documentation, a tour of your site, and formal and informal interviews with randomly selected managers, supervisors, and employees. OSHA then prepares its findings in a report, including recommendations, and presents the findings at a closing conference.
The first thing to do when an OSHA compliance officer arrives at your facility is to examine the inspector’s official credentials and identification. You may request a photo ID. You should record the identifying information, and then contact the local OSHA office to verify the credentials. You should then provide the inspector with a room where they may work, and treat them cordially as you would any guest visiting your offices. It is best to take a friendly attitude in dealing with OSHA, however, management is within its right to enforce limitations and restrictions in accordance with the type of inspection OSHA is conducting.
You should then notify your company’s main office and inform the appropriate personnel (e.g., general manager, supervisors, safety personnel) of an impending inspection. If supervisory personnel are not available, you may ask the inspector to return at another time to ensure they can be provided with the information they are requesting, however, the inspector may ask employees for written documentation at this time.
After the appropriate personnel have been assembled, the OSHA inspector will conduct an opening conference where they will define the scope of the onsite inspection, clarifying expectations, and explaining what assistance will be required from site personnel. If a complaint has been filed with OSHA, the inspector will share a copy of the complaint (although the name of the complainant will be redacted; OSHA prohibits any form of discrimination by employers against workers based on anything they say or show the compliance officer during the inspection).
The OSHA inspector will then review documentation of your safety and health programs to determine if they adequately address hazards at the site and if they meet OSHA requirements. At the very least they will ask to see the following:
- Injury and illness summary (OSHA 300 logs) for the past three full calendar years, plus year-to-date records (if your industry is not exempt from keeping these records). (To determine if you are exempt, click on http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12791http://.)
- Specific injury reports for each employee’s injury for the past four years
- A written Hazard Communication Plan
- Documentation of employee training
- Material Safety Data Sheets for hazardous chemicals that you use or store on site
- Any documentation related to the reason for their visit such as written programs, training logs, and inspection and maintenance logs of equipment.
This is a not an inclusive list, and inspectors may request additional documents and records for review. You should note all documentation reviewed. Then the inspector will tour your facility.
Check back next Friday to learn what will be involved with the on-site inspection, and how best to handle OSHA’s visit.
To learn more about OSHA compliance, as well other training courses provided by TCS, visit our website at www.tcs-inc.us.