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What to Expect When
OSHA is Inspecting
Paul McNeill
Senior Safety Consultant
Hello!
I am Paul McNeill.
- Safety Consultant @ Insperity
- Former Compliance and Safety Health Officer for
OSHA
- Featured in Safety and Health Magazine published
in June 2019 "what to expect when OSHA is
inspecting,” as 1 of 2 former OSHA inspectors
offering advice
2
Overview
● Background
● Case Studies
● Preparing for OSHA
● Inspection
○ Opening conference
○ Walkthrough
○ Employee Interviews
○ Closing conference
● Takeaways
● Contact Information
3
Background
4
5
Background
OSHA recovery response for
Hurricane Katrina and World
Trade Center
Risk assessment and risk
management (Insperity)
Consulting engagements for
reducing risk and costs and
mock-style OSHA inspections
(Insperity)
In-depth Safety and
Health Audits for USPS
of largest automated mail
processing plant
Implements safety
programs and safety
awareness training
(Insperity, OSHA)
What is OSHA?
6
MISSION STATEMENT:
“...Ensure safe and healthful working conditions for
working men and women by setting and enforcing
standards and by providing training, outreach,
education and assistance.”
Only 73,000 out of 3,000,000
Companies have OSHA inspections per year
7
1 bad inspection could cost
in the $100,000s
CASE #1
❏ Greets and accompanies OSHA
inspector during visit
❏ Asks questions about any citations
given
❏ Shares results with employees
❏ Corrects any citations
CASE STUDIES
8
CASE #1
❏ Ignores OSHA inspector
❏ Continues previous task during
OSHA visit
❏ Passively involved in inspection
❏ Disregards and doesn’t correct
citations
$350,000 FINE
HIGH
COMPLIANCE
Preparing for OSHA
9
Drawing OSHA’s attention
10
Imminent
danger
Injuries
&
illnesses
Complaints
Hazardous
workplaces
Referrals
Follow-up
The Scary 13
11
“
The 11th Commandment of OSHA:
“‘if it’s not in writing, it never happened.’”
12
Preparing your workplace
13
❏ Safety and training programs in place
❏ Documentation
❏ Activity and equipment safety
❏ Injury and illnesses logs
❏ Items specific to your industry
❏ Get a consultation
❏ Designate a neutral, cordial host
❏ Check OSHA inspector credentials
❏ The Scary 13
❏ Designate place for employee interviews
post-inspection
The Inspection Process
14
Inspection Process
1. Opening
conference
15
2. Walkthrough
3. Employee
Interviews
4. Closing
Conference
When inspector arrives...
16
❏ Correct small hazards
❏ Clear areas in front of
❏ Walkways
❏ Exit doors
❏ Fire extinguishers
Facility has ~1 hour before inspection must begin.
Take this time to:
Opening Conference
1. Reason for inspection
If complaint, will show
document with identifying party
redacted
2. Describe scope and
procedure for walkthrough
Any hazard can be noted, even if not
addressed in a complaint
17
Walkthrough
Inspector takes photos/videos
➔ Host should mirror
inspector and ask
questions
Inspector asks a question and I
don’t know the answer
➔ Best practice:
“Let me get back to you on that. I
don’t want to give you the
incorrect answer.”
What to do if...
For OSHA host:
Employee Interviews
Topics covered
★ Basic information about employee
★ Safety training received
Supervisor may/may not be present
★ This is left up to the employee
being interviewed
Minimize work interruptions
★ Inspector will do their best not to interfere
with work duties
★ They will wait until employee is available
19
Closing Conference
20
Results via phone 1-6 weeks after visit
Refer employer to free consultation service to assist in making corrections
Results post-correction sent via mail
Corrective actions posted nearby sites of citations for employee awareness
Sign certified letter (step 3)
Redeem yourself - there’s hope!
21
❏ OSHA Quick-Fix Penalty Reduction Program
❏ Meet with area OSHA director*
* must be within 15 days of final results via mail
Takeaways
22
1. Don’t fake it - be prepared by establishing written programs and
training beforehand
2. Designate a cordial, neutral host
3. Know the Scary 13
4. Actively participate in the process
5. Make corrections promptly
6. Take advantage of the consultation and “penalty-relief” options
23
Takeaways
Thanks!
Any questions?
Drop me a line via my Linkedin or email
postalpaul5@hotmail.com
24

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What to Expect When OSHA is Inspecting / Paul McNeill

  • 1. What to Expect When OSHA is Inspecting Paul McNeill Senior Safety Consultant
  • 2. Hello! I am Paul McNeill. - Safety Consultant @ Insperity - Former Compliance and Safety Health Officer for OSHA - Featured in Safety and Health Magazine published in June 2019 "what to expect when OSHA is inspecting,” as 1 of 2 former OSHA inspectors offering advice 2
  • 3. Overview ● Background ● Case Studies ● Preparing for OSHA ● Inspection ○ Opening conference ○ Walkthrough ○ Employee Interviews ○ Closing conference ● Takeaways ● Contact Information 3
  • 5. 5 Background OSHA recovery response for Hurricane Katrina and World Trade Center Risk assessment and risk management (Insperity) Consulting engagements for reducing risk and costs and mock-style OSHA inspections (Insperity) In-depth Safety and Health Audits for USPS of largest automated mail processing plant Implements safety programs and safety awareness training (Insperity, OSHA)
  • 6. What is OSHA? 6 MISSION STATEMENT: “...Ensure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”
  • 7. Only 73,000 out of 3,000,000 Companies have OSHA inspections per year 7 1 bad inspection could cost in the $100,000s
  • 8. CASE #1 ❏ Greets and accompanies OSHA inspector during visit ❏ Asks questions about any citations given ❏ Shares results with employees ❏ Corrects any citations CASE STUDIES 8 CASE #1 ❏ Ignores OSHA inspector ❏ Continues previous task during OSHA visit ❏ Passively involved in inspection ❏ Disregards and doesn’t correct citations $350,000 FINE HIGH COMPLIANCE
  • 12. “ The 11th Commandment of OSHA: “‘if it’s not in writing, it never happened.’” 12
  • 13. Preparing your workplace 13 ❏ Safety and training programs in place ❏ Documentation ❏ Activity and equipment safety ❏ Injury and illnesses logs ❏ Items specific to your industry ❏ Get a consultation ❏ Designate a neutral, cordial host ❏ Check OSHA inspector credentials ❏ The Scary 13 ❏ Designate place for employee interviews post-inspection
  • 15. Inspection Process 1. Opening conference 15 2. Walkthrough 3. Employee Interviews 4. Closing Conference
  • 16. When inspector arrives... 16 ❏ Correct small hazards ❏ Clear areas in front of ❏ Walkways ❏ Exit doors ❏ Fire extinguishers Facility has ~1 hour before inspection must begin. Take this time to:
  • 17. Opening Conference 1. Reason for inspection If complaint, will show document with identifying party redacted 2. Describe scope and procedure for walkthrough Any hazard can be noted, even if not addressed in a complaint 17
  • 18. Walkthrough Inspector takes photos/videos ➔ Host should mirror inspector and ask questions Inspector asks a question and I don’t know the answer ➔ Best practice: “Let me get back to you on that. I don’t want to give you the incorrect answer.” What to do if... For OSHA host:
  • 19. Employee Interviews Topics covered ★ Basic information about employee ★ Safety training received Supervisor may/may not be present ★ This is left up to the employee being interviewed Minimize work interruptions ★ Inspector will do their best not to interfere with work duties ★ They will wait until employee is available 19
  • 20. Closing Conference 20 Results via phone 1-6 weeks after visit Refer employer to free consultation service to assist in making corrections Results post-correction sent via mail Corrective actions posted nearby sites of citations for employee awareness Sign certified letter (step 3)
  • 21. Redeem yourself - there’s hope! 21 ❏ OSHA Quick-Fix Penalty Reduction Program ❏ Meet with area OSHA director* * must be within 15 days of final results via mail
  • 23. 1. Don’t fake it - be prepared by establishing written programs and training beforehand 2. Designate a cordial, neutral host 3. Know the Scary 13 4. Actively participate in the process 5. Make corrections promptly 6. Take advantage of the consultation and “penalty-relief” options 23 Takeaways
  • 24. Thanks! Any questions? Drop me a line via my Linkedin or email postalpaul5@hotmail.com 24