It is a rainy, dreary Monday. You had to change a flat tire in the rain. You are drenched and you think “What else will happen today?” You get to work and start to enjoy that first cup of coffee when you are notified someone from OSHA is at the Front Desk. NOW WHAT?
In the event you are inspected by state or federal OSHA, here are some helpful tips for what is next.
Nine steps to take when the OSHA inspector or compliance officer arrives
- Be cordial – greet the Compliance Safety and Health Officer (CSHO) and ask to see their credentials. Compliance Officers are not offended by this request.
Oftentimes, documents such as, last three (3) years of OSHA 300 logs, Hazard Communication program and training documents are asked for.
Have your documentation in order so it can be retrieved quickly.
- Notify Leadership of the visit and pull together the team. The CSHO may also want to include members of the Safety Committee or hourly employees.
- The CSHO will conduct an Opening Conference and explain the reason for the visit. The reason may be an employee complaint, a scheduled inspection, or any number of other reasons.
- After the Opening Conference, the Compliance Safety and Health Officer will conduct a walkaround inspection. If the CSHO is there to look at a specific piece of equipment or operation, show the CSHO that operation. If it is a wall-to-wall inspection, take copious notes and pictures of anything the CSHO notes.
- During the walkaround inspection the CSHO and accompanying representatives will inspect the facility for potentially hazardous conditions. The CSHO will discuss possible corrective actions. Remember, the CSHO may talk with employees at any time. DO NOT COACH employees on what to say.
- At the end of the inspection the CSHO will conduct a closing conference. During this conference the findings, possible corrective actions, timelines, citations and penalties will be explained. The CSHO will explain approximate timeframes for the official report.
- Take any initial findings and begin remediating as quickly as possible. It is not necessary to wait for the official report.
- If you feel the findings are in error, there is an appeals process that will be explained during the closing conference.
- You may need additional assistance. Seek out intra-company resources, outside consultants or contact the state or federal OSHA office for consultation and guidance.
Top ten signs your OSHA inspection isn’t going well
To lighten up this topic a bit, here are the Top Ten Signs Your OSHA Inspection isn’t going well. (Author Unknown)
10. OSHA sets up temporary housing in your parking lot.
9. The Compliance Officer mutters, “This is unbelievable” each time he or she enters a different department.
8. OSHA calls in a professional film crew to document conditions in the plant and a reported from “60 Minutes” tags along.
7. The Compliance Safety and Health Officer insists on wearing a moon suit supplied with SCBA, while your employees work in jeans and tennis shoes.
6. The Congressman you call for help won’t return your call but does return your campaign contribution.
5. The Compliance Officer begins the opening conference with “You have the right to remain silent.”
4. The Compliance Officer asks you a specific question about a report in your files, but you haven’t turned any over yet.
3. The Compliance Officer knows each of your employees by first name.
2. The Compliance Officer is a former employee that you fired.
1. The Secretary of Labor conducts the closing conference.