Are You Prepared for an OSHA Inspection?
The Occupational Safety and Health Administration (OSHA) conducts inspections without advance notice. Companies should have an established procedure that will be followed when an OSHA inspector shows up. This should include the person who will escort the inspector around (owner, safety manager or plant manager), as well as an employee representative.
There are several things that could prompt an OSHA inspection:
Imminent danger situations – any condition where there is reasonable certainty that a danger exists that can be expected to cause death or serious physical harm immediately
Fatalities and catastrophes – investigation of incidents that involve a death, or the hospitalization of three or more employees
Referrals of hazard information from other federal, state, or local agencies, individuals, organizations or the media
Complaints/allegations of hazards or violations – employees can request anonymity when they file complaints
Programmed/planned investigations – these are aimed at specific high-hazard industries, workplaces that have experienced high rates of injuries/illnesses, or emphasis programs
Follow up inspections
The assigned escort should be taking notes while the inspector is talking. If the inspector takes photos, the assigned escort should do the same so that both parties have a similar record of what has transpired. The inspector may also ask to interview employees to ascertain their views on the state of safety programs and knowledge of employees. Employer representatives are excluded from these interviews.
After the walkaround is completed, a closing conference is held with the employer and the employee representative to discuss the findings and possible courses of action needed.
Proposed penalties will be provided at the time of the issuance of citations, which may occur up to six months after the initial visit. It is important to keep the line of communications open during the whole investigation and to provide actions taken to correct any issues to OSHA as they are completed.
Further information on OSHA inspections can be found at www.osha.gov