The OSHA Inspection Preparation Process
Edwin Zalewski, Senior Editor - Safety
An OSHA inspection may not be avoidable, but your company can avoid OSHA citations. The best way to do that is by:
- Ensuring regulatory compliance.
- Conducting hazard assessments and safety audits and correcting any hazards found.
- Developing and implementing a written safety and health program.
- Training employees to protect them from safety hazards.
- Keeping accurate records.
- Performing self-inspections to identify safety issues before OSHA does!
An inspector’s primary task during an inspection is very simple: To find non-compliance issues. If they don’t find any, they won’t issue a citation. And if they do find violations, remember that the officer can choose to expand the scope of the inspection. Therefore, it is paramount you identify the requirements that apply to your workplace. Also, stay abreast of regulatory changes. Being in compliance now doesn’t mean you will always be in compliance. Regulations and policies change and new ones are issued. OSHA has issued several proposed and final rules over the last five years. The most significant final rule was Walking-Working Surfaces, which included major fall protection, training, and inspection requirements that affect every general industry employer.
Conducting routine hazard assessments is an excellent way to find hazards in the workplace before OSHA does. Focus on the Big Four: falls, electrocutions, caught-in or between, and struck by. OSHA is placing increased focus on these hazards, which are the leading causes of fatalities. In the past, OSHA focused on these hazards only in the construction industry, but now OSHA is targeting these four hazards in general industry as well.
SAFETY AND HEALTH PROGRAM
The benefits of developing and implementing a safety and health program are varied and many, but perhaps the greatest benefit is reducing injuries and illnesses. According to the U.S. Department of Labor, businesses spend $170 billion a year on costs associated with occupational injuries and illnesses, which comes straight out of company profits. But workplaces that establish a safety and health program can reduce their injury and illness costs by 20 to 40 percent, and better yet, reduce their likelihood of being inspected by OSHA.
If not done already, establish a written injury and illness prevention program that outlines the hazards in the facility and how they are controlled. This is another way to “find and fix” hazards before OSHA finds them.
Ensure employees are trained for the tasks they perform. OSHA compliance officers are now verifying not only that required training has been conducted, but that the training was provided in a format that workers could understand. If you customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English, you will need to provide safety and health training to employees in the same manner.
For example, if employees are not literate, telling them to read training materials would not satisfy an employer’s training obligation. There cannot be any barriers or impediments to understanding. If this means that your company has to provide training in other languages, then that is what has to be done.
OSHA says that if a reasonable person would conclude that necessary training had not been conveyed to employees in a manner they were capable of understanding, then the violation may be cited as serious.
As stated, one of the first things an OSHA compliance officer will do during an inspection is review records. Obviously, keeping accurate records is another way to avoid an OSHA citation. Very importantly, focus on injury and illness records. OSHA always reviews these records at the outset of an inspection to determine areas on which to focus. Remember, if your industry as a whole has fewer injuries and illnesses, you and your industry will be less likely to be targeted by OSHA for an inspection.
Inspections are typically done by walking around a facility and focusing on a particular safety issue, such as machine guarding, fire extinguishers, chemical storage, forklifts, falls, etc. Through the inspection, you are able to specifically determine whether or not OSHA requirements have been met. The goal of any inspection should be to find any and all deficiencies and get them corrected before they lead to an incident or an inspection by OSHA. This ensures ongoing safety compliance because there is a constant check for problems in the workplace.
For these reasons, self-inspections may be viewed favorably by OSHA. A thorough inspection with proper follow-up can signal that a company is complying with applicable regulatory requirements.
Edwin Zalewski, Senior Editor - Safety
Ed specializes in topics such as injury and illness recordkeeping, powered industrial trucks, and walking working surfaces. His work has appeared in Bloomberg Businessweek, Monster.com, Occupational Safety & Health, and newspapers such as the New York Post, Atlanta Journal-Constitution, Denver Post, and Pittsburgh Post-Gazette.
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