BE PREPARED
Common Reasons for an OSHA Inspection photographs and / or documents containing information about trade secrets will remain confidential.
• Discuss the process for conducting employee interviews and producing documents. If possible, schedule employee interviews so shifts are covered.
• Ask the CSHO to make all requests for company information and documents in writing. Your company’ s legal counsel should review all requests for documents and information as well as all information and documents provided.
• Gather your inspection equipment. DURING THE WALK-AROUND
• Begin the walk-around. Make sure everyone has the required PPE and is following the proper safety protocols of the site.
• Keep the route as limited as possible.
• Understand the plain view doctrine. This means a CSHO can investigate any hazard observed while walking through the premise.
• Document the CSHO’ s findings and your own findings by taking detailed notes.
• Make sure to take pictures, samples, and measurements of anything the CSHO takes, and at the same time. Your company can request that samples and monitoring take place at a time when the company can conduct its own sampling and monitoring.
• Complete“ quick fixes” right away. If you or the CSHO identifies any quick fix items, have them taken care of immediately. The CSHO will take these actions as proof of your company’ s willingness to comply with safety and health laws.
• Do not interfere with employee interviews. The CSHO has the right to conduct employee interviews in private. Employee interviews may involve labor representatives, rankand-file employees, and management personnel. If there is an interview with a company decision-maker, then it is highly encouraged to have a representative present as any statements made are considered binding admissions on the employer.
DURING THE CLOSING CONFERENCE
• Request copies of all OSHA samples and monitoring reports from the CSHO.
• Imminent danger situations
• Fatalities or severe injuries reported to OSHA
• Worker complaints
• Referral inspections( other agencies, third parties or media)
• Programmed( targeted or follow-up) inspections
• OSHA 300 Form for the current year and the previous five calendar years
• OSHA 300A Form for the previous five calendar years
• Injury and incident reports for the current year and the previous five calendar years
• OSHA 301 Forms( Most state workers’ compensation forms are acceptable substitutes.)
• Completed training programs
• Safety data sheets( SDSs)
• Written safety compliance programs
26 • SpectrumInsGroup. com