Knock! Knock! OSHA's at the door

Every year OSHA inspects thousands of workplaces from coast to coast. Of course, with so many businesses operating in each OSHA region and so few inspectors, the odds of being visited by OSHA are quite small for most employers. But since you never know, it is always best to be prepared. And to be well prepared, you need to appreciate the who, why, when, what and how of the inspection process, as well as your role in preparing for an inspection.

Who inspects?

Inspections are handled through the OSHA area office in your region and conducted by OSHA compliance officers. These inspectors are experienced professionals with a comprehensive background in industrial safety and health problems and solutions.

Their goal is to help employers and workers identify and reduce on-the-job hazards â€” not to nail employers or slap companies with big fines, although that can happen to companies that donâ€™t make a concerted effort to comply with OSHA standards.

Inspectors may bring along specialists or consultants knowledgeable in a particular field of safety and health to help them with the inspection.

Why do they inspect?

OSHA says that one of the key ways it promotes worker protection is by conducting workplace inspections. In service of that objective, there are several possible reasons why OSHA inspectors might knock on your door:

An employee has made a complaint about worksite safety. If the complaint alleges imminent danger, this becomes a top priority for OSHA.

A complaint may also be made by someone other than an employee, such as a former employee or concerned citizen.

A fatality has occurred and has been reported as required.

Itâ€™s a regularly scheduled inspection. This is most likely if you are in a high-hazard industry that is currently a major OSHA focus. Some 4,000 high-hazard worksites were targeted for unannounced comprehensive safety and health inspections last year.

Itâ€™s a follow-up visit, perhaps to determine if prior violations have been abated.

When do they inspect?

Donâ€™t expect advance warning of an OSHA inspection. Inspectors can show up any time during regular business hours.

There are some exceptions, however. For example, youâ€™ll get advance warning of an inspection while the inspectors are en route to your facility if thereâ€™s an imminent-danger situation that requires immediate abatement. Or, you might get a call from the area office if OSHA believes the inspection can most effectively be carried out after regular business hours or if the agency thinks that prior notice will result in a more complete and efficient inspection.

What do they look for?

Inspectors are looking for violations of OSHA standards. Exactly what kind of violations depends on the nature of your operations and the particular hazards of your workplace. However, during the past few years, the most often cited OSHA violations for general industry have featured safety and health problems related to:

Hazardous chemical information and training [1910.1200]
Machine guarding [1910.212]
Lockout/tagout [1910.147]
Personal protective equipment [1910.132]
First-aid and eyewash facilities [1910.151]
Walking-working surfaces [1910.23]
Respiratory protection [1910.134]
Electrical wiring [1910.305]
Powered industrial trucks [1910.178].

Furthermore, an inspection can be comprehensive or focused:

Comprehensive inspections cover basically the whole facility.

Focused inspections are limited to certain areas, operations, conditions or practices. For example, if the inspection is triggered by an employee complaint, the inspection would be limited to the issues involved in the complaint. But, of course, a focused inspection can always be expanded depending on what inspectors find.

How is it done?

A fairly standard inspection agenda is as follows:

Step 1: Credentials â€” When inspectors arrive, they first present their credentials to the facility manager. Although companies have the right to require a warrant at this point, most prefer not to take a confrontational stance and simply invite the inspectors to enter the facility.

Step 2: Opening conference â€” During a brief opening conference with members of management and employee representatives, compliance officers explain the nature and purpose of the inspection and indicate the scope of the inspection and the records they wish to review. If the inspection was triggered by an employee complaint, the inspectors will provide a copy of the complaint, but not the employeeâ€™s name.

Step 3: Examination of records â€” The inspectors will then ask to examine the OSHA 300 Log and other accident and illness reports. They might additionally ask to see such things as the hazard communication program, lockout/tagout procedures, fire safety programs, and so on. Theyâ€™ll also check to make sure that OSHA safety and health posters are appropriately displayed.

Step 4: Walk-around inspection â€” During the walk-around inspection, inspectors will look for violations of specific OSHA regulations. They will probably want to talk to employees â€” they have the right to do so, and so do employees. They can even talk privately if they wish.

If the inspectors want to talk to the employer, be courteous and cooperative, but make sure the safety manager or some other member of upper management is on hand for guidance in what to say â€” and what not to say.

Step 5: Closing conference â€” The inspection wraps up with a closing conference during which the inspectors review any violations and discuss possible methods and timetables for correction. Inspectors will describe the companyâ€™s rights and responsibilities and answer any questions at this time. Theyâ€™ll also explain that violations could result in a citation and fines (but thatâ€™s up to the head of the area office â€” not the inspectors).

So donâ€™t panic when the OSHA inspector comes knocking at your door. Knowing what to expect and being prepared will help ensure that an inspection goes smoothly.