Expert presentation on how to handle an OSHA Inspection. Learn best practices for planning, hosting an OSHA auditor and maintaining a safe and compliant workplace.
5. OSHA Has Been Busy
• OSHA Conducted 92,000 inspections
• There were over 188,000 violations cited
• There was approximately $240 million in
penalties
6. Top 10 Violations
1. Hazard Communication
2. Respiratory Protection
3. Electrical ‐ Wiring and
Equipment
4. Powered Industrial Trucks
5. Lockout/Tagout
7. 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
11. Organize Internal Resources
• Preparedness Coordinating Committee
• Facility Program Managers/Experts
• Facility Inspector Escorts
• Logistics and Planning
• Roles & Responsibilities
• Communications
12. 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
13. 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
14. 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
16. 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
17. 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
18. 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
19. 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
20. 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
21. 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
22. 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
23. 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)
24. 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
33. Be Ready!
• 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
34. 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..
35. 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
36. 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