This document provides guidance on preparing for an OSHA audit. It outlines common OSHA violations, tips for organizing resources and preparing documentation, guidelines for escorting OSHA during inspections, and ensuring compliance with OSHA training regulations. Being prepared in advance of an inspection and having proper documentation and plans in place are key to a successful OSHA audit.

1. What to do to prepare for
an OSHA Audit

2. Meet the Speaker
Rick Foote

3. OSHA Has Been Busy
• OSHA Conducted 92,000 inspections
• There were over 188,000 violations cited
• There was approximately $240 million in
penalties

4. Top 10 Violations
1. Hazard Communication
2. Respiratory Protection
3. Electrical ‐ Wiring and
Equipment
4. Powered Industrial Trucks
5. Lockout/Tagout

5. Top 10 Violations
6. General Machine Guarding
7. Electrical Systems Design
(General)
8. Personal Protective
Equipment (General)
9. Fall protection (Guarding
Floor/Wall Openings and
Holes)
10. Exit routes

6. Are you ready for OSHA to
knock at the door?

7. OSHA Inspections:
Preparation is Key!

8. Form a Committee
• EH&S
• Facilities Dept.
• Maintenance
• Environmental Services
• Clinical Lab
• Researcher Admin.
• Radiology
• Pharmacy
• Plant Operators

9. Organize Internal Resources
• Preparedness Coordinating Committee
• Facility Program Managers/Experts
• Facility Inspector Escorts
• Logistics and Planning
• Roles & Responsibilities
• Communications

10. Inspection Preparedness
Coordinating Committee
• Organizes and facilitates the Opening
Conference
• Works out schedule with the inspectors
• Coordinates inspections with
department/program managers
• Conducts daily debriefings
• Organizes and facilitates the Closing
Conference

11. Facility Inspector Escorts
• Introduces the inspector and convey
seriousness of the interview.
• Intercedes when leading questions
are asked during an interview
• Tactfully restates misunderstood
questions to interviewee.
• Doesn’t allow unqualified people to
respond to questions

12. OSHA Inspections - Tips
• Be Prepared!
• Maintain up-to-date plans and records
• Know where documents are; be able to produce them in a
timely manner
• Have a Preparedness Plan
• Records and Documentation Review
• Assemble materials requested by OSHA
• Identify conference room (do not use offices) for records
review
• Offer only requested documents for specific locations
• Make duplicate copies of records that they copy

13. The Inspection

14. Inspections: Logistics
and Planning
• Internal Notification (“The
British are Coming”)
• Enacting the Preparedness
Plan
• Opening Conference
• Coordinating a schedule
with OSHA
• Debriefings with parties
inspected

15. Opening Conference
• State that the group has been assembled to help
facilitate the inspectors’ review & provide an open
communication channel with key facility officials
• Outline positive working relationship with OSHA
inspectors
• Discuss how important compliance is to your facility
• Who in upper management is involved and how
often your department meets with them
• Obtain an understanding of inspection scope

16. Guidelines: Site Inspection
• Identify nature and scope of inspection
• Accompany each inspector at all times
• Cooperate, but do not offer information not
requested
• Duplicate all records copied
• Take good notes, photographs, split samples
• Monitor employee interviews
• Conduct an exit interview for each area to
get an idea of what they found

17. Facility Escort Guidelines
• Restate unclear answers from the
interviewee to the OSHA inspector.
• Stay by the inspectors side
• Take notes
• During and shortly after the interview
• Of issues that the inspector notes during the
inspection
• Of questions that could not be answered

18. Taking care of business
• Fixing Potential Violations
• As issues are found
• Prior to OSHA entry
• Before OSHA finishes for the day
• Behind the Scenes During the Inspection
• OSHA Location during the day
• Fielding questions

19. Closing Conference
• Consider having VP level
representative and
attorney present
• Present documentation of
correction actions taken
during the inspection
• Have answers to questions
that couldn’t be answered
in the field

20. More Guidelines
• Take notes
• Don’t attempt to deal with hypothetical situations
• “Fix” simple deficiencies along the way
• Make a copy of anything given to the inspectors
• Seek approval for all photos requested by the
inspectors; take duplicate photos
• Likewise, take duplicate samples

21. Guidelines Continued…
• Don’t offer an opinion or agree/disagree with
the inspectors
• Do talk about sports, music, general topics
• Don’t be their “buddy” or confidant
• Don’t sign anything
• Keep them from harm’s way (no confined
space entry or near high hazard areas)

22. Guidelines Continued…
• Don’t offer information unless specifically asked
• Don’t argue with the inspectors
• Don’t complain about the regulations
• Don’t be pushed into giving an answer if you don’t
know…say that you don’t know
• Don’t be evasive. Answer directly and succinctly
• Don’t lie to the inspectors or misrepresent what
really happens in your area
• Don’t engage in speculation

23. Training Requirements

24. OSHA Regulations Requiring Training
• 1910.38 - Emergency Action
Plans
• 1910.39 - Fire Prevention
Plans
• 1910.66 - Powered Platforms
for Building Maintenance
• 1910.95 – Occupational
Noise Exposure
• 1910.106 – Flammable and
Combustible Liquids
• 1910.109 - Explosive and
Blasting Agents
• 1910.110 - Storage and
Handling of Liquefied
Petroleum Gases
• 1910.111 - Storage and
Handling of Anhydrous
Ammonia
• 1910.119 - Process Safety
Management of Highly
Hazardous Chemicals
• 1910.120 - Hazardous Waste
Operations and Emergency
Response

25. OSHA Regulations Requiring Training
• 1910.124 - General
Requirements for Dipping
and Coating Operations
• 1910.132 – Personal
Protective Equipment
• 1910.134 – Respiratory
Protection
• 1910.142 - Temporary Labor
Camps
• 1910.145 - Specifications for
Accident Prevention Signs
and Tags
• 1910.146 – Permit Required
Confined Spaces
• 1910.147 – The Control of
Hazardous Energy (lockout-
tagout)
• 1910.151 - Medical Services
and First-Aid
• 1910.155 – 1910.165 – Fire
Protection (includes portable
fire extinguishers)

26. OSHA Regulations Requiring Training
• 1910.177 - Servicing of Multi-
Piece and Single-Piece Rim
Wheels
• 1910.178 – Powered
Industrial Trucks (forklift
operator training)
• 1910.179 – Overhead and
Gantry Cranes
• 1910.180 – Crawler,
Locomotives and Truck
Cranes
• 1910.181 – Derricks (material
handling)
• 1910.183 – Helicopters (for
material handling)
• 1910.184 – Slings (material
handling)
• 1910.217 – Mechanical
Power Presses
• 1910.218 – Forging
Machines
• 1910.252 – 1910.255 –
Welding, Cutting and Brazing

27. OSHA Regulations Requiring Training
• 1910.261 - Pulp, Paper, and
Paperboard Mills
• 1910.262 – Textiles
• 1910.264 - Laundry
Machinery and Operations
• 1910.265 – Sawmills
• 1910.266 – Logging
Operations
• 1910.268 –
Telecommunications
• 1910.269 - Electric Power
Generation, Transmission,
and Distribution
• 1910.272 – Grain Handling
Facilities
• 1910.332 – 1910.333 –
Electrical Safety Related
Work Practices
• 1910.410 – 1910.440 -
Commercial Diving
Operations

28. OSHA Regulations Requiring Training
• 1910.1000 – Toxic and
Hazardous Substances
• 1910.1001 – Asbestos
• 1910.1003 – 1910.1016 –
Thirteen Carcinogens
• 1910.1017 – Vinyl Chloride
• 1910.1018 – Inorganic
Arsenic
• 1910.1020 - Access to
Employee Exposure and
Medical Records
• 1910.1025 – Lead
• 1910.1026 - Chromium (VI)
• 1910.1027 – Cadmium
• 1910.1028 – Benzene
• 1910.1029 - Coke Oven
Emissions
• 1910.1030 – Bloodborne
Pathogens
• 1910.1043 – Cotton Dust

29. OSHA Regulations Requiring Training
• 1910.1044 - 1,2-Dibromo-3-
Chloropropane
• 1910.1045 - Acrylonitrile
(Vinyl Cyanide)
• 1910.1047 - Ethylene Oxide
• 1910.1048 – Formaldehyde
• 1910.1050 –
Methylenedianiline
• 1910.1051 - 1,3-Butadiene
• 1910.1052 - Methylene
Chloride
• 1910.1096 – Ionizing
Radiation
• 1910.1200 – Hazard
Communication
• 1910.1450 - Occupational
Exposure to Hazardous
Chemicals in Laboratories

30. Preparedness

31. • Develop an OSHA
compliance calendar
• Ensure all of the required
written plans are up to date
• Develop a training matrix
• Keep records organized
and ready for inspection
Be Ready!

32. Be Ready!
• Review the OSHA 300 Log
• Conduct internal
inspections
• Involve employees to get
their buy-in
• Enforce programs such as
personal protective
equipment, safety devices,
etc..

33. Industrial Client
• We did a survey to help identify potential
OSHA compliance issues and to train
employees on what to do when they arrive
• We identified numerous issues that needed
to addressed by client
• OSHA did a site visit several months later
and the facility was found to have no
violations in there program

34. Higher Education Client
• The client was visited by OSHA regarding an
employee compliant
• We assisted the client with responding to the
complaint and then correcting the issue
• We also trained the staff on what to do when
OSHA comes back onsite
• OSHA did a follow up inspection and
commended them for the thoroughness of
the response

35. Questions?
Rick Foote
rfoote@triumvirate.com
617-686-6184

36. Thank You!
1-888-TEI-WOWS www.triumvirate.com

37. Eliot, ME
Lowell, MA
Somerville, MA
Portland, CT
Astoria, NY
Woodstown, NJ
Jeannette, PA
Baltimore, MD
Ashland, VA
Orlando, FL
Davie, FL
Locations