Preparing for Possible OSHA Inspections in 2020
OSHA can show up at your work site for an inspection at virtually any moment, without any notice in advance. This is why it is so important for employers to always be ready for the possibility of an inspection.
The best way to prepare for an inspection is to ensure your worksite is up-to-date with current OSHA guidelines at all times. Worksites should be compliant for the type of industry and work that is performed.
While in most instances these inspections are done by chance, many conditions can prompt an OSHA inspection. These include a workplace death or catastrophe, complaints from employees, referrals from other workplaces or government agencies and follow-up inspections.
OSHA doesn’t target any one business or industry for inspections, but industries with high risk jobs are often prioritized for OSHA inspections based on reported fatalities and serious injuries.
OSHA conducts these inspections with the purpose of determining whether or not employers are striving to comply with proper OSHA standards that ensure employees have a safe and healthy workplace.
An OSHA inspection should not be a chore to prepare for. In reality, it is simply a way to further improve the safety of your workers in ways you should already be doing.
There are a lot of potential dangers in the workplace and OSHA’s standards simply ensure that no one has to come to work fearful of getting hurt. Preparing for potential OSHA inspections, regardless of whether or not you are chosen for an inspection, has lots of benefits for both the employer and employees and makes a safer and healthier workplace.
Many assume that it is important to be ready for OSHA inspections simply to save on any fines that may occur, but being ready for an inspection simply means that you are following the below steps to ensure the safety of your workplace
What to Expect From an OSHA Inspection
Setting your expectations for what will occur during an OSHA inspection and knowing what to do during an inspection will help ensure things run smoothly.
OSHA Inspector Arrival
When the inspector arrives, you should first confirm their identification. An OSHA ID includes the inspector’s photo, name and office. If you are unsure of whether the inspector is truly from the government, you can also call your local OSHA office to check.
The length of the inspection will depend on the size of your workplace as well as the focus of the review. Throughout the inspection you should conduct yourself in a professional manner. While OSHA inspectors will not accept any bribes, behaving in a friendly and calm way can help the progression of the inspection.
The inspection itself will be broken up into three phases; an opening conference, a walk-through of the facility and a closing conference.
Your Pre-Inspection Meeting
Select a meeting place for the opening conference, this should include the owner or safety manager along with an employee representative. The opening conference will allow the inspector to go over the specifics of the inspection to explain the parameters of the inspection, what will be inspected and if the inspection was prompted by any complaints.
At this time, the inspector will also ask for information on the work your worksite performs, the number of employees, names of those in leadership positions and contact information. They may also request files on injury and illness logs and record keeping.
The Walkthrough
The next step of the inspection is the walk–through. During this phase of the inspection, they are simply looking for any potential hazards that could lead to the death, illness or injury of an employee.
During the walk-through, the officer will point out any violations that need to be immediately corrected and check to ensure that all required OSHA posters and signs are properly posted. The inspector will try to minimize any interruptions to your work schedule and that of your employees throughout the walk-through.
The Closing Conference
Finally, the last phase of the inspection is the closing conference. This gives the inspector the opportunity to discuss any changes or courses of action that need to take place afterward and provide the employer with information on refuting citations and penalties.
How to Always be Prepared for an OSHA Inspection
Going through the process of preparing your workplace will not only ensure you are ready for any unforeseen inspections, but also reduce accident rates.
One of the biggest aspects of being prepared for an OSHA inspection is being organized and methodical in your recordkeeping. There should be a log of all illnesses, injuries and fatalities that occur while on the job including any documentation of emergency preparedness plans, evacuation procedures, lockout/tagout programs, exposure and medical records and material safety data sheets.
Beyond this, employers should also take steps forward in preparing for an inspection by assigning responsibilities. Delegating different roles to ensure there are specific employees educated on different aspects of the inspection such as preparing the proper paperwork and escorting the inspector around the building will be very beneficial in the case of an actual inspection.
Having a designated employee escort the inspector through the inspection also allows them to document everything the inspector does. This includes taking note of any conversations and observations as well as taking pictures of anything the inspector also photographs.
It is also helpful for this employee representative to bring a small dry erase board and marker to identify any objects that are hard to recognize in photos. This is helpful for your own recordkeeping and with the process of appealing any wrongful citations.
Most Cited Osha Regulations For 2019
- Hazard Communication 3,671
- Scaffolding 2,813
- Lockout/Tagout 2,606
- Respiratory 2,450
- Ladders 2,345
- Machine Guarding 1,743
Source: nsc.org
Understanding the Results
Any citations and penalties from the results of your inspection must be received within 6 months of the violation. If you have taken all of the above steps in advance and receive a citation you feel is not consistent with your workplace you can appeal it depending on the category it is listed under.
Citations are listed as either willful, serious, other-than-serious, de minimis, failure to abate and repeated. These different categories determine the likelihood of receiving adjustments to the penalty. For example, any willful citation will not receive an in good faith adjustment, whereas serious violations may have the penalty reduced based on the gravity of the penalty.
You’ll have the opportunity to appeal your claim in a conference with the OSHA Area Director and discuss any penalties and abatement dates. This gives you a chance to come to an agreement on how to eliminate the hazard moving forward. OSHA is very willing to work with you on this stage because their main priority is always eliminating hazards rather than giving penalties.
To avoid having to appeal any violations, be proactive and periodically check that you are compliant to eliminate any potential citations if you are inspected. There are a wide variety of resources that employers can utilize as they work towards preparing for an inspection. These include training software and supportive products and services.
Remember the old adage, “an ounce of prevention is worth a pound of cure.”? The same is true for your OSHA inspection. Taking proper precautions from the beginning, especially when safety is involved can save you from future problems. At National Safety Compliance, we feature easy and affordable solutions for your safety training. We offer complete training kits in DVD, USB, and via Instant Digital Access, as well as on-demand LMS. All of our training kits are available in English or Spanish, and include Program Outlines, Quizzes, Certificates, Training Logs, Wallet/ID Cards, Compliance Guides, PowerPoint Presentations, and a manual. You can use them as many times as you like, because all of the materials are easily printable.