After the passing of the 1970 Occupational Safety and Health Act, Congress established the agency known as the Occupational Safety and Health Administration — or OSHA — within the Department of Labor to help ensure safe working conditions for private sector employees. In addition to providing education, training and assistance, OSHA is also responsible for conducting workplace inspections that may be the result of accidents, complaints or just a mandatory scheduled inspection.
HOW TO PREPARE FOR AN OSHA INSPECTION
Whatever the reason for a visit from OSHA, it’s important for safety managers in the construction industry to be well-prepared for inspections and not feel singled out by them. After all, the ultimate goal of an inspection is to ensure that your employees are working in safe conditions.
Clearly, when a compliance safety and health officer — or CSHO — is scheduled to conduct an inspection, you want to be properly prepared for the visit. Keep in mind that CSHOs are federal employees whom you should always extend sufficient respect to. It’s also critical to note that with only a little over 2,100 OSHA inspectors responsible for approximately 130 million workers nationally, you should avoid wasting a CSHO’s time.
With that said, you should also be aware of your rights and how to act responsibly so that any OSHA inspection you’re involved in goes as smoothly and productively as possible. Read on to learn more about how to conduct yourself appropriately and answer the question, “What does OSHA look for in an inspection?”
OSHA INSPECTION CHECKLIST
As the construction industry is responsible for one in every five work-related deaths, OSHA has even titled the most common fatality causes in the industry — falls, electrocutions, being struck by an object and getting caught in or between objects — the “Fatal Four.” Consequently, any inspection conducted by a CSHO will understandably be focused on those dangers — as well as other related workplace factors that you have the right to be informed of.
Remember, safety inspections by OSHA are in place to keep everyone at your facility safe, make sure working conditions are optimal and ultimately ensure your business's compliance and success. Keep that fact as well as the following points in mind as a checklist for being prepared for an OSHA inspection:
- Check IDs: Since CSHOs are federal employees, they each carry a government-issued identification card as well as official business cards — both of which you should ask for and verify as soon as a CSHO arrives at your facility and/or worksite.
- Ask why: You have the right to be informed of the reason for any OSHA inspection. If it’s not offered, ask the CSHO politely for the scope and reason for their visit.
- Grant permission: Before beginning, the CSHO must ask your permission to conduct the inspection. It’s highly advisable that you grant permission after notifying your appropriate managers. Remember that not granting permission will only raise suspicions with the inspector, who will then most likely return with a warrant to inspect — and quite possibly additional inspectors.
- Do not demonstrate: While you want to listen closely to all conversations and keep every piece of paperwork the CSHO gives you, it’s not advisable to offer anything — in written form or oral statements — that’s not required of you. The inspectors are busy professionals who are only there to see your daily operations, not equipment outside of those operations.
- Accompany walkarounds: Once the inspection begins, you should make sure a qualified member of your staff accompanies the CSHO throughout your building. If more than one inspector is working, each should be accompanied by a staff member — and under no circumstances should you or your employees perform any type of special demonstrations for the CSHOs, as doing so would be outside of the inspection's purpose. The CSHOs are merely there to observe and inspect.
- Document everything: From taking careful notes to capturing photographs, it’s vital to document as much as possible about the inspection. If you need more time to write down notes, ask for it — it’s your right to do so.
- Tell the truth: Throughout the entire process, it’s imperative that you tell the truth when you're responding to a CSHO’s questions — especially in interviews. Stick to the facts and refrain from offering your opinions or estimates regarding things like working conditions and/or timelines for making corrections, as the process should be accurate.
- Know the deadlines: While OSHA has six months from the time of an inspection to issue citations, employers who receive citations have only 15 working days to respond — by either contesting the citations or paying any associated fines.
What Does OSHA Look for During an Inspection?
Now that you know how to prepare for an OSHA inspection, it's important to understand what OSHA inspectors will look for during your evaluation. When you know what elements impact your assessment, you'll be able to make the necessary preparations to ensure that your workplace is safe and up to code.
Every OSHA inspection varies, which means you can never fully predict exactly what your inspector will review during your assessment. However, most examiners will look for 10 particular hazards when observing your workplace, so the chances are good that OSHA will examine some or all of the following factors during your inspection:
- Sources of motion: Your inspector may look for parts and components that move with a rotating, transverse or reciprocating motion. Make sure your machines are free of exposed projections like bolts, set screws, abrasions and nicks that can intensify safety risks.
- Sources of high temperature: Equipment that produces high temperatures could pose fire hazards. If you notice that one of your machines is particularly hot, consider whether that temperature is normal or a sign of a malfunction.
- Sharp objects: OSHA employees will look for sharp edges and blades that can cause harm to workers. Be sure to guard all sharp objects in your facility, equip your staff with personal protective equipment (PPE) and practice safe working procedures around these components.
- Rolling objects: Rolling objects are considered crushing hazards, as they can injure those they crash into. You should inspect these items and ensure that you have the proper safety measures in place to prevent them from hurting someone.
- Harmful dust: Dust can create numerous safety risks in the workplace, such as slipping, respiratory and combustion hazards. Make sure to properly ventilate and clean your workplace to prevent dust buildup.
- Falling objects: Any item that could potentially fall from an elevated location due to improper placement or maintenance is considered a falling hazard. You can minimize these risks by implementing barriers, guards, safety nets and other protective devices.
- Slippery surfaces: Slip, trip and fall hazards are some of the most common causes of workplace injuries. There are several ways to reduce these risks, such as redirecting dripping liquids, installing non-slip materials, purchasing floor mats and providing workers with high-traction footwear.
- Chemical exposure: Most industrial job sites have hazardous chemicals present. You can practice chemical safety by storing chemicals properly, requiring staff to wear PPE, giving access to safety data sheets, installing emergency showers and eyewashes, and putting an emergency action plan into place for chemical spills and exposure.
- Electrical hazards: It's crucial that you comply with OSHA's general electrical requirements and electrical safety standards to reduce hazards. You should also assess all wiring and machines and take them to qualified electricians for service if you notice an issue.
- Workplace layout: The way your workplace is arranged can impact job site safety. For example, it can be dangerous for hazardous substances to be placed in close proximity to one another.
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