Risk & Business Magazine Bowen Miclette & Britt Summer 2018 | Page 7

OSHA INSPECTIONS very seriously. This may be the single most common reason why OSHA will conduct an inspection at the workplace. OSHA will maintain strict confidentiality with respect to the individual filing the complaint. You must not retaliate against any employee whom you suspect may have filed the complaint. 4. Referral A referral may come from various sources, not just an employee or former employee. The public, the media, a federal/state/local agency, a doctor, or an employee’s family member may file this complaint. 5. Programmed Inspections These inspections are aimed at specific high-hazard industries or occupations and are referred to as Local or Regional Emphasis Programs. Some of the more current Emphasis Programs include Upstream Oil and Gas Industry, Construction, Cranes used in Construction, Manufacture of Metal Products, High Noise in Manufacturing, Fall Hazards in Non-Construction, Heat Illness, Grain Handling Facilities, Health Hazards in Healthcare Industry, and Poultry Processing Facilities. 6. Follow-Up This inspection determines if a previously cited employer corrected the violations received in an earlier inspection. 4 STAGES There are four stages of an OSHA inspection: 1. Opening Conference 2. Examination of Records and Written Programs 3. Inspection of Facility 4. Closing Conference BE PROACTIVE The key to survival is preparedness. Prepare your employees by developing a Positive Safety Culture within your company. Since employee complaints are the #1 reason for OSHA inspections, it only makes sense that if your employees feel “ownership” in their safety program, they are less likely to complain about it. Executives and managers must show their commitment to the Positive Safety Culture and lead by example. Implementing a Positive Safety Culture is easy and starts with a few key steps: provide proper training, encourage participation in internal safety audits, and always follow through on internal safety complaints. Have your safety staff or a third-party safety consultant perform a pre-audit. This will give you a better idea of where to improve your safety processes. Any areas of concern should be addressed and documentation of the corrective actions should be maintained. DOCUMENT, DOCUMENT, DOCUMENT Documentation is always vital in the inspection process. As the old saying goes, if it wasn’t documented, it didn’t happen. Internal audits, JSAs, hazard analyses, SDSs, corrective actions, safety programs/ processes, training logs, and incident reports are all easy to document and maintain for recordkeeping. Don’t forget your OSHA 300 and 300a logs too (rest assured, you will be asked for these during an OSHA audit). It is important to know where these documents are upon request. Don’t wait to figure it out during the audit. SMILE AND WAVE Always greet the compliance officer in a friendly and courteous manner. You have the right to ask the compliance officer for their credentials. You may also ask for the reason of the inspection. The compliance officer may ask to speak to your employees alone; allow them to do so in a quiet area, if possible. There is no need to worry what your employee will say if your Safety Culture is Positive. Elect at least one person to accompany the compliance officer during the proce ss and have maintenance or other staff correcting items as you go along, if possible. STRIKE A POSE During the audit, the compliance officer will take pictures of their findings. You have the right to take pictures as well. Take pictures from the exact angle as the compliance officer did as well as a few other angles and distances, in case you need them to explain a larger or more complete story. Make sure you are also taking notes during the audit; you will want to review them during the corrective action process. SEND THEM OFF WITH A SMILE At the closing conference, the compliance officer will review their findings and any violations, deadlines, and potential fines with you. This is not the time to argue. Remember the old saying: you catch more flies with honey than you do with vinegar. If you are not in agreement with the officer, you have the opportunity to speak to the area director and discuss abatements, dates, and additional information relevant to the audit. If OSHA chooses to issue citations and financial penalties for violating standards, it must do so within six months of the violation’s occurrence. ASK FOR HELP If the thought of OSHA showing up for a visit still makes you nervous, ask for help. The Risk Management staff at BMB has years of experience with OSHA audits. Schedule a pre-audit with one of our staff members and let us assist in easing your mind. + Chanda Chaney joined BMB Risk in June 2013. She brings over 20 years of Industrial Safety experience with a specialty in Hazardous Chemicals and Oil and Gas. Previously she was the lead HAZWOPER instructor for the National Safety Council, Level II Loss Control for Texas Mutual and owner of her own Safety Consulting business as well as being an adjunct Safety instructor for Navarro College and Kilgore College. She currently sits on three committees for the ASA Houston chapter and the Safety committee for the ABC Houston chapter. 7