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