OSHA, or Occupational Safety and Health, can launch a surprise inspection at any notice. An OSHA audit would likely be due to a failed inspection, or a safety issue happening in the workplace. It’s important to always be compliant and prepared for a potential OSHA inspection.
OSHA’s website states “OSHA is committed to strong, fair, and effective enforcement of safety and health requirements in the workplace. OSHA inspectors, called compliance safety and health officers, are experienced, well-trained industrial hygienists and safety professionals whose goal is to assure compliance with OSHA requirements and help employers and workers reduce on-the-job hazards and prevent injuries, illnesses, and deaths in the workplace. Normally, OSHA conducts inspections without advance notice. Employers have the right to require compliance officers to obtain an inspection warrant before entering the worksite.”
As you can imagine, there are a number of different workplaces, on a varying scale of mild risk to severe risk of hazard or injury. OSHA wants to focus its efforts on the most hazardous workplaces first, and utilize six levels of priority. In order of importance: imminent danger situations, severe injuries and illnesses, worker complaints, referrals of hazards from other agencies, individuals, or organizations, and finally targeted and follow-up inspections. More information and descriptions of each situation can be found on the OSHA Inspection Fact Sheet.
If you treat every day as if that’s the day OSHA comes to inspect your workplace, you will be in good shape. First of all, the OSHA website contains all materials, training, resources, and contacts you could possibly need to be safety compliant. To prep for an OSHA inspection, try the following steps to avoid a surprise, and disorganized workplace when that time comes.
In-House Training and Continuing Education
Ensuring your employees are well versed in the laws, regulations, and safety compliance procedures is your first line of defense in passing any OSHA inspection, but more importantly maintaining a safe, injury-free workplace. First Response Safety Trainers provide OSHA certified training courses and resources for all employers, and before engaging in any potentially hazardous activities, all workers must receive OSHA standardized safety training. They can even receive an OSHA card indicating they received OSHA-authorized training in either 10 or 30-hour courses. This isn’t required in all places, nor guarantees hire if employees hold an OSHA certified training certification.
Let’s say your workplace is a hospital laboratory. You have workers in the lab, but also workers in an office setting. It’s likely you have lab employees walk through an office, and office workers walk in a lab setting. It’s very important that all team members, regardless of their work area, know the laws and regulations of safety throughout the entire department. The same goes for construction companies that may have a receptionist or office staff, who doesn’t work in the field, but need to be safe passing through those areas. They also need to know how to keep the construction workers safe and be able to act appropriately.
Define Laws & Regulations
There will be different laws and regulations for all industries, in both public or private sectors. Your employees, especially those closest to any hazardous materials and activities should be familiar with the laws and regulations. Some industries, like construction, are going to have a massive list, that no person could memorize, or be expected to, but they need to be reviewed, and be easily accessible to all employees. They should be able to look up the rules for ventilation for example, within minutes.
Posting Necessary Signage
OSHA requires proper signage to be posted near hazards in the workplace. They have guidelines of what they require (colors, fonts, verbiage), and where they should be placed. Below is a quick breakdown, but more information can be found on the OSHA website, and also in this handy infographic produced by Graphic Products.
DANGER SIGNS must be placed where a hazard poses an immediate danger and special precautions must be taken.
CAUTION SIGNS must be posted to warn of potential hazards; they may also be used to caution against unsafe practices.
SAFETY INSTRUCTION SIGNS should be used wherever general instructions and safety suggestions can help workers perform their tasks in a safe manner.
Monthly Compliance Checklist
Once a month, employees and employers should go through a checklist of all compliance items to be fully prepared for any inspection. They can go through signage, test employee knowledge, cover safety procedures, safety clothing, and PPE, etc. A safety officer can be designated to be in charge, and be the main point of contact if an OSHA inspection ever occurs.
On top of the monthly compliance checklist, inserting quarterly “mock inspections” could be an great way to be 100% prepared for an inspection or audit. Using materials from the OSHA Inspection Fact Sheet, you can do a full run down of the procedure. At this time you should assign responsibilities to your team in terms of safety checks and audit run-downs, perform hazard assessments, and safety training with the team.
Know Your Rights
Lastly, it’s important to know your rights as a company, and as employees. Let employees know they don’t have to talk to OSHA, it is not required. It is encouraged that employees answer any questions from OSHA honestly, but are not under any obligation or requirement to speak with the inspectors. Lastly, they can refuse to be recorded by any OSHA investigators. When or if OSHA surprises your company with a visit, you should first ask for their credentials, and if you want to make sure they are who they say they are, you can call the local OSHA director to confirm the inspection and inspector identity. Employers are allowed to put the OSHA inspector in a room while they alert staff, vendors, contractors, etc. on-site that OSHA is there for an inspection. During the inspection, keep steady notes on what they do, what they ask, and how they conduct the inspection – these notes will come in handy in all future interactions and for future safety training. Lastly, keep in mind that inspectors cannot issue citations, only the area director can do so, but they can discuss any problems they find during the closing conference before their departure.
If you have any questions about how to be OSHA compliant or how to get your employees properly trained, give us a call at 651-423-9255.