Preparing for and Surviving an OSHA Inspection: Are you ready?
By Bill Taylor, CSP
Many employers have established plans so they will be ready when the OSHA inspector arrives, unannounced. We at CTJ Safety certainly encourage this but in addition, every employer should ask if they have done all they can to prepare by protecting workers. After all, that is the reason for the inspector’s visit-to determine if the employer is trying to protect workers and if those protection efforts are adequate. The sad truth is that many employers think their efforts are adequate when all the while they are not-employees are still being injured. They determine that many of the injuries are the fault of the worker rather than take an introspective look to identify problems within their management system. They feel secure in knowing they are doing a good job of complying with OSHA standards.
As we all know, and OSHA will be the first to say, OSHA standards are the bare minimums and not enough to keep workers safe. They are the foundation on which employee protection efforts should be built. A good example is the machine guarding standard which does not require employers to guard machinery or moving equipment which is seven feet or more above the work surface. Yet most employees today are capable of reaching seven feet into the air and able to reach the hazard. So while the unguarded chain and sprocket 84 inches above the floor is legal, it still presents a hazard to workers within its reach. And while it may not garner an OSHA citation and penalty, it can still cause injury.
The most important thing any employer should know about preparing for and surviving an OSHA inspection is that their focus should be on worker protection rather than OSHA compliance. If an employer is doing whatever they need to do to protect workers then they are meeting their moral as well as their legal obligation, as they will, in many cases, exceed OSHA requirements. It also shows a good faith effort and may help foster goodwill which can help keep penalties to a minimum.
Before the Inspection
- OSHA law is the bare minimum. Identify as many hazards as possible and correct them, regardless of what is required by OSHA. Do what is necessary to protect workers and compliance will take care of itself.
- Determine what required written programs you should have and develop or purchase them. CTJ Safety can provide employers with a list of required and implied written programs such as lockout/tagout, hearing conservation, confined space entry, etc. We can also provide pre-written programs for employers to adapt.
- Assure all records (training, inspection, etc.) are well organized and accessible.
- Develop a plan for an OSHA visit including responsibilities of those who will likely be involved.
During the Inspection
- Be courteous and professional. This is a law enforcement officer. Treat him/her as such.
- Answer all questions as truthfully as possible and try to provide whatever he/she asks for without volunteering information.
- Verify identity of the compliance officer by checking photo ID.
- Have someone accompany the compliance officer at all times for his/her safety and to answer questions.
- Do not argue with the compliance officer. If there is disagreement request an informal conference at which time you can offer explanation or defense.
- Yes, employers have a right to require a warrant. This is not recommended.
After the Inspection
- Don’t wait until you get your citations to correct violations. Do it right away. If there are violations then there are hazards and hazards should be corrected as soon as possible.
- Everything is negotiable. Don’t be shy about requesting extensions of abatement dates, reduction of penalties, etc.
- Avoid repeat violations. Fix it once and make sure it stays fixed.
- CTJ Safety consultants are experts at hazard recognition and also training in hazard recognition. In addition to inspections and audits conducted on-site we also teach various techniques to enable workers to have an on-going ability to identify hazards within their own workspaces and activities.
- CTJ Safety can provide a complimentary list of written programs required and implied by OSHA. We can also provide prepared written programs which employers can adapt for their own use.
- As a part of our audit services we can examine employer training and inspection records to determine the effectiveness as well as adequacy.
- CTJ Safety can provide a written plan which employers can implement when the OSHA inspector arrives.
- We can assist employers in many ways after they have received OSHA citations.
Contact CTJ Safety and let us tell you how we can help you protect your most important resourceyour employees.
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