A number of situations can prompt
an OSHA inspector’s visit. These include
major accidents and catastrophes,
on-the-job fatalities, employee and whistleblower complaints, high work-related
injury and illness rates and previous
citations; or it could be a follow-up visit.
They can also be triggered by referrals
from outside entities, such as subcontractors or government agencies. Other
work sites are simply selected at random.
An inspector can show up at any time.
A vast majority of inspections occur with
no advanced notice. Therefore, employers should have a plan in place if the
situation arises. The plan should identify the person or people responsible
for greeting and escorting the inspector
around the job site. In most cases, this
would be the staff safety professional or
It is also the right of the employees to
have a designated representative present
throughout. Often, at larger organized
sites, union labor contracts dictate this.
The plan should also include a predetermined location where all parties can sit
and discuss the inspection and the work
site. This may occur in a conference
room, large office or work trailer.
In the event that the appropriate parties are not available when an inspector
arrives, they should be asked if rescheduling is possible. However, just in case,
a backup plan should be in place. It is
important that more than one employee
is versed in the safety nuances of each job
site so that they are able to adequately
accompany an inspector.
Knowing what to do when an OSHA
inspector arrives will help the process
move along smoothly and likely result in
fewer violations. Inspectors may show
up dressed casually or formally. Be sure
to ask for identification to verify that
they are who they say they are. If there is
any uncertainty, contact the local OSHA
office to ensure they are legitimate.
Once the inspector’s identity is confirmed, have them sit down, and notify
the proper personnel. This will prevent
them from wandering around the work
site unattended, looking for violations.
Inspector escorts would be well-advised
to ask about the scope of the inspection
and the reason for the visit. Inspectors
are often only interested in seeing a specific area. Knowing why and what they
are looking for can be tremendously
helpful. The goal is to show as little of
the work site as possible. In addition, if
the inspection is occurring as a result of
a complaint, the employer has a right to
request a copy of that complaint.
Typically, thorough inspections only
occur when all of the following four criteria are met:
1. An employee complaint is received.
2. The business is in a high injury rate
3. The employer has a lost workday
rate at or above the national average.
4. OSHA has not carried out a
complete safety inspection during
the last two years.
During the inspection, take notes and
record everything. In the event that the
inspector photographs something, have a
camera available and attempt to recreate
it. The inspector is trying to build a case
that a violation has occurred. It can be
very helpful to quickly identify and cor-
rect any hazards observed during the visit.
However, do so without admitting guilt.
By law, employers are required to
keep and maintain electronic and paper
records, and they should be organized
and available if an inspector wishes to
see them. This may include injury and
illness records, a hazard communication
program, and emergency preparedness
and evacuation procedures. This type of
documentation should only be offered if
specifically requested. Having inaccurate
and disorganized records can raise red
flags and result in citations and a more
thorough review of the work site.
Ensure that employees know how
to respond if they are asked a ques-
tion. Questions should be answered
truthfully without volunteering unnec-
essary information. In the event that an
employee does not know the answer to a
question, he or she should be instructed
prior to the inspection to respond by say-
ing something to the effect of, “I’ll have
to check and get back to you on that.”
Employees also have the right to refuse
to respond, request the presence of man-
agement before speaking or even have a
private discussion with the inspector.
Practicing good housekeeping is
important, too. A messy work site can
give the appearance of recklessness and
result in additional work hazards.
Finally, be nice and courteous! This
should be a no-brainer, but being polite
and easygoing can result in a less-critical
Ready for Your Close-Up
Be prepared for an OSHA inspection
THE LIKELIHOOD OF GETTING INSPECTED by the Occupational Safety and
Health Administration (OSHA) is pretty low. In fact, each year, state and federal
agencies conduct roughly only 100,000 job site inspections. Regardless, it’s still
important to create a safe work environment free from occupational hazards and
to be prepared should an inspection occur.
O’CONNO R is safety and regulatory affairs manager for Intec, a safety consulting, training
and publishing firm that offers on-site assistance and produces manuals, training videos and
software for contractors. Reach him at email@example.com. I S T