Written by Jeff Pacheco - Falcon Safety Group.
Prepare for the Visit
In preparation for an on-site OSHA inspection, OSHA compliance officers will research the workplace that they will visit, look over previous site inspections, take notes of any citations or specific areas of concern, industry operations, and various compliance that may apply to the workplace.
Following this preparation, the inspectors will know what types of personal protective equipment will be necessary, if any, along with testing equipment. The OSHA inspectors would then be ready to safely inspect all necessary aspects of the workplace. Keep in mind the inspectors are qualified Environmental Health and Safety professionals that understand the standards and any applicable guidelines from the NFPA, ANSI, NIOSH, or DOT.
When arriving at the on-site inspection, the OSHA compliance officers will display their credentials to the employer and explain why the inspection is taking place and the scope of the entire inspection. They must share with you their scope, otherwise they may have free rein of the whole facility.
During the Visit
After the scope of the inspection is explained, the inspector, with the employer and employee representatives (if union), performs a walk-through of the workplace. It is at this stage in the process that potential hazards will be inspected. At this stage only have senior level management part of the inspection that would have limited knowledge of the process. Do not share processes, opinions or thoughts that may lead to the inspectors interpreting that the employers may not have assessed the hazard.
Compliance to specific OSHA standards will also be inspected. This could include the posting of required postings, the use of necessary safety equipment like safety googles or high-visibility vests, and that proper monitoring of hazards is carried out.
Throughout the walk-through, OSHA inspectors can consult with employees privately to discuss the safety of the workplace. However, the employer has the right to be present during questioning of any employee deemed management, and the employer shall make it very clear of disrupting production shall be limited as much as possible.
Keep in mind that any request of material from the compliance officer should be in writing before any information is given. Letting them know that you will send them the information by the next business day. This will give you some time to review what evidence you will be supplying them. During this time, having a third-party post OSHA inspection is recommended. This process will give the employer the possible thought process of the inspector and what they are looking for.
After the Visit
After the walk-through, the compliance officer will discuss some of the findings of the inspection with the employer and employee representatives. It is now that OSHA may make some minor recommendations to the employer to correct immediately, along with possibly proposed penalties and citations in the future. They will not give you any indication of what the final citations or penalties may be. They will have 180 days from the date of inspection to put together their case for penalties and citations. If necessary, a follow-up inspection could be scheduled. During this phase, if they want to come back to reinspect or test, have a third-party safety representative to be present to ask relevant questions that pertain to the actual inspection. Follow-ups are usually requested to add on more possible citations.
Have questions or need help preparing for an OSHA inspection? Contact IMEC!
