When OSHA arrives at your facility, the compliance officer will explain why it was targeted for inspection and should explain the scope of the inspection, the purpose and standards and, if applicable, provide a copy of the employee complaint.
In most cases – unless an accident has just happened or there's been some sort of tip to non-compliance – the inspectors will want to see paperwork first. This means they'll check injury-reporting logs, training records and sometimes personnel files should these include parts relevant to who works in high-risk areas. Then inspectors will examine the workplace itself, usually looking for signage and equipment compliance.
Employee anonymity is always maintained. The employer will be asked to select an employer representative to accompany the compliance officer during the inspection. An authorized representative of the employees, such as a union steward, also has the right to attend the inspection. The destination and duration of the inspection are determined by the compliance officer and will usually consist of a methodical inspection of the facility. The compliance officer may consult with a reasonable number of employees, privately if desired. This is where your safety program is most likely to reveal weaknesses, as employees can be asked a series of questions related to the complaint or general questions about their understanding of your company's safety program. They will be informed that OSHA prohibits discrimination in any form by employers against workers because of anything they say or show the compliance officer during the inspection.
Questions might include:
-the employees' safety orientation,
-specific job training,
-safety meeting occurrence,
-understanding of safety rules,
-what employees have been trained to do in case of an accident or emergency,
-whether employees feel that their job function is safe.
During the course of the inspection, the inspector will typically ask to see your required written programs, training records, evidence of certification (where required), chemical inventories (if applicable), MSDS and OSHA 300 Log. The inspector may request copies of these and other documents as well, which you are obliged to supply. So know where these documents are kept and keep them in good order.
During the closing conference, the inspector will discuss all non-compliant conditions identified and violations for which you may be cited. You will have the opportunity to produce records that show compliance efforts or that will assist OSHA in determining the time needed for abatement of the hazards. The inspector will not indicate any proposed penalties as penalties are determined by the area director. You must post a copy of each citation received at or near the place in which the violation occurred. It must remain there for 3 days or until the violation is abated, whichever is longer.
Jeff Jensen
The Contractor Qualification Expert
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3 comments:
This is really good information. I am co-owner of a relatively small contracting company and have not yet been OSHA inspected. We are starting to get bigger contracts and anticipate an OSHA inspection will take place shortly. What should we expect working with OSHA to be like? Are they friendly and personable?
Generally smaller companies are inspected based upon a major incident or employee compliant. I have had good experiences with Osha, but I have also had some good one's with the IRS too so you should watch the "friendly" attitude as they generally aren't there to be friends. The best advice I could give you is to do things correctly as an employer from the start and you will never have to worry about it. Osha has lots of free information that they can provide you in what your requirements are as an employer. I would recomend you use these and follow them. They are easy to do and will save you some headaches down the road while showing your employees that you truly care about their safety and not just how much money you make. There is nothing worse as a small employer than going to the wife of one of your workers and telling her that her husband was killed or inured serioulsy while working for you. Do the right thing and you can't go wrong.
sorry. made a typo. I meant employee complaint! This is quite common if employees do not feel that the employer is addressing their concerns or are just disgruntled.
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