Preparing for an inspection by the Occupational Safety and Health Administration (OSHA) is like preparing for an emergency. You do not want to wait until the event occurs to figure out what to do.
This is not to suggest you should initiate drills for an inspection, but you should plan for and periodically address OSHA inspections in your training programs. Employees should know their rights under OSHA, and when and how an inspector may decide to conduct a site visit.
You might see an inspector for many reasons, such as:
- A random computer-generated inspection
- A National Emphasis Program inspection
- An employee complaint investigation
- A fatal or serious work injury
- An injury incident rate over the national average
- A high-risk industry inspection with a focused agenda (such as heat stress)
- An invitation to inspect, such as when you are applying for Voluntary Protection Program status
Regardless of the reason for the inspection, there are certain actions you can take and plan for.
Check your compliance with the regulatory standards
There are documents that every OSHA inspector has the right to request and obtain. You should have those documents readily available. If you are not sure what they are or whether you have them ready for an inspector to view, download a checklist of required OSHA documents and conduct an internal audit. Find or create them, and ensure they are current. (For example, check emergency phone numbers, leadership names and titles, etc.)
Know what an inspector can ask to see
Never just open your cabinet drawers or computer files thinking you have nothing to hide. That will not benefit you.
There are mandatory documents and nonmandatory documents. The mandatory documents are what the regulations and law state you must have and show to an inspector upon request. Examples are your:
- 300A injury summary
- Chemical inventory list under the hazard communication standard
- Required written plans
- Training records on chemicals and first aid
- Crane and forklift certifications
- Medical surveillance and exposure records
Many of OSHA’s Top 10 Most Frequently Cited Standards have to do with nonexistent or out-of-date written plans or procedures. Examples include the lockout/tagout (LOTO) and hazard communication standards. These Top 10 standards never change. While companies should be working to avoid the same citations that are repeated every year, that doesn’t seem to be the case.
Keep nonmandatory documents to help you comply with mandatory items
An inspector normally cannot be privy to nonmandatory documents unless they are part of a complaint or criminal investigation. Even then, the inspector must have cause to review them.
Nonmandatory documents include internal audit records, calibration records for sensors and monitors, industrial hygiene sampling results and training syllabi, to name a few. Remember these documents can be discoverable for certain investigations, but you should never offer them up voluntarily.
Conduct a personal protective equipment risk assessment
Include a personal protective equipment (PPE) risk assessment with your document audit. If you issue PPE for known hazards, you must have a document that demonstrates why you need PPE, what PPE is needed, and which work areas or assigned tasks it applies to. Not having this assessment sets you up for trouble!
Document workplace and mobile equipment pre-shift inspections
With your audit trail, document workplace examinations and mobile equipment pre-shift inspections. Keep two weeks’ worth to prove your employees do them but do not retain months’ or years’ worth.
Train your employees on what to expect from an OSHA investigation
During an inspection or investigation, the inspector will interview employees, asking questions about emergency and LOTO procedures, how to locate safety data sheets, and how they can get safety concerns addressed. Employees may also be asked if they know their OSHA rights, as this is a required training topic. Knowing what is being asked of them and why keeps employees from wondering whether they are in trouble or what the company may have done wrong.
Develop and follow a written document retention and destruction policy
When a document ages out, immediately shred or delete it from your files. Just like your tax returns and records, keeping them forever is a storage nightmare and an inspector’s dream.
Encourage employee participation in safety
Let your employees help you identify hazards and offer front-line suggestions on how to address them. This creates employee buy-in and keeps your facility safer.
Preparing for an OSHA inspection is not complicated. Train your employees, conduct audits, and retain and destroy documents on an established schedule.