HOME/HELPFUL TIPS/How to be ready for a OSHA Inspection

How to be ready for a OSHA Inspection

By Dave Malter, President, Malter Associates, Inc.

OSAH Inpsection

OSHA compliance is something that is expected from everyone every day. Will you and your workplace be ready when the inspector comes to your door?

Let’s explore three key issues of OSHA inspections:

1) Why?

Reasons why an OSHA inspection could occur at your facility.

2) What?

Programs and documents OSHA inspectors will ask to examine when they arrive at your workplace.

3) How?

Things that you can do to effectively manage the inspection process.

OSHA Inspections will occur as the result of:

1. Imminent Danger

2. Employee fatality

3. Employee multiple inpatient hospitalization

4. Employee complaint

5. Agency referral (e.g., fire department)

6. Targeted Inspections (due to elevated DART and DAFWII Rates), or

7. National Emphasis Program (e.g., explosive dusts)

An Imminent Danger is a workplace hazard that puts you at immediate risk of death or serious physical harm

An employee or referral complaint is often the cause of an OSHA inspection. At least one of the following eight criteria must be met for OSHA to conduct an on-site inspection based on an employee or referral complaint:

  1. A written, signed complaint by a current employee or employee representative with enough detail to enable OSHA to determine that a violation or danger likely exists that threatens physical harm or that an imminent danger exists;
  2. An allegation that physical harm has occurred as a result of the hazard and that it still exists;
  3. A report of an imminent danger;
  4. A complaint about a company in an industry covered by one of OSHA's local or national emphasis programs or a hazard targeted by one of these programs;
  5. Inadequate response from an employer who has received information on the hazard through a phone/fax investigation;
  6. A complaint against an employer with a past history of egregious, willful or failure-to-abate OSHA citations within the past three years;
  7. Referral from a whistle blower investigator; or
  8. Complaint at a facility scheduled for or already undergoing an OSHA inspection.

Sometimes OSHA sends a letter to you instead of conducting an on-site inspection. If that happens, you will receive a letter from OSHA identifying allegations of violations of one or more OSHA regulations. Generally, OSHA is requesting that the location manager respond to the facts surrounding these allegations within fifteen working days. Failure to do so may result in an inspection of the facility.

What?

When OSHA arrives at your door, after they present their identification to you they will conduct an opening conference. After the Opening Conference, OSHA Inspectors will generally:

Key inspection areas often include:

Topic

Documents

• Work Related Injuries and Illnesses

• OSHA 275, 275A, 301

• Current, plus past 5 YR

• Training

• Emergency Management

• Evacuation Plans

• Response Plans

• Emergency Drills

• Training

• Hazard Communication

• Written Program

• MSDS/SDS

• Contractors

• Training

• Personal Protective Equipment

• Hazard Assessments

• Selection

• Training

• Lockout and Tagout

• Machine Specific Lockout Procedures

• Periodic Inspections

• Contractors

• Training

• Electrical Safety

• Electrical Safe Work Practices (plus 70E)

• Training

• Powered Industrial Trucks

• Classroom Training

• Driver’s Evaluations

• Post-Accident/Near Miss/Observation
Follow-up Training

• Modification/Rerating Certifications

• Vehicle Inspection Records

• Respiratory Protection

• Air Sampling Results

• Appendix D

• Medical Evaluations

• Respirator Selection

• Fit Tests

• Periodic Observations/ Inspections

• Training

• Noise and Hearing Conservation

• Noise Sampling Results

• Engineering/Administrative Controls

• Audiometric Testing

• Hearing Protector Selection

• STS Management

• Training

• Machine Guarding and Power Press Safety

• Operator, Maintenance, and
Supervisor Training

• Lockout Procedures

• Lockout By-Pass Procedures

• Set-up (e.g., Die Setting) Procedures

• Machine Safeguard Inspections

• Cranes and Slings

• Frequent Crane Inspections

• Periodic Crane Inspections

• Periodic Sling Inspections

• Modification/Rerating Certifications

• Training

How?

You must be proactive to minimize the potential impacts of an OSHA inspection. Ask yourself a few simple questions:

When you receive an inspection, Rule #1 is cooperation. It is a good policy to cooperate fully with federal and state OSHA personnel and to permit them to conduct proper investigations within the scope of their authority. They are usually there for a legal purpose and your cooperation will generally make the process easier for both parties. But, this is your facility and there is a lot that you can influence during the process.

Do’s and Don’ts

Slide Products, Inc. • PO Box 156 • 430 Wheeling Road • Wheeling, IL 60090
Toll Free 1-800-323-6433 • 1-847-541-7220 • Fax 1-800-756-7986 • Email Slide Products
© 2019 Slide Products, Inc. All rights reserved.