Ten Tips To Surviving An OSHA Visit
By Susen Trail | 06/12/2022
Even though the number of OSHA Enforcement Officers as a ratio to the number of businesses is extremely small, one could show up at your door without notice. In that case, you need a plan because, trust me, you don't want an Enforcement Officer to know your employees don't know who is in charge of managing the company's safety and health hazards. You'd be surprised how often in my Enforcement years I was left wandering around a workplace looking for the Safety Manager, and I'd usually have double digit violations noted by the time I met him or her.
- Never let them wait, and especially never let them wander around alone! To prevent this, you must make sure everyone in your company knows who is in charge of Safety in your workplace, and who the back-up is in case that person is at lunch.
- Always have an 'understudy' for your Safety Manager. If no one else knows where your Hazard Communication Program is it basically means the Program has not been implemented.
- It is also handy that everyone knows who and where the Safety Manager is in case of emergency.
- Be polite, and listen more than you talk.
- You might learn something.
- You might say something that gives the wrong impression.
- You might give the correct impression about hazards they had not thought of yet.
- Planning to fix a hazard is a Willful Violation. You know your employees face a controllable hazard every day and you know you are in violation of an OSHA standard. This means real money. Also, what are you waiting for: Injury, illness, or death?
- Even if you know they are incorrectly citing a standard do not correct them. However, always look up the scope of the standard or paragraph of the standard after the Compliance Safety and Health Officer (CoSHO) leaves.
- Sometimes I found the perfect language for an uncontrolled hazard in standard only to find that the scope did not fit the conditions at the workplace. So, I could not write the violation.
- When the report comes make sure they are citing the correct standard. Keep in mind that construction standards, 1926, apply in General Industry workplaces for activities such as redecorating, painting, etc.
- If you have a Safety Consultant, never have them talk to the CoSHO in your stead. Never say, or imply, your Safety Consultant knows the status of your safety compliance better than you do.
- It's like telling the police officer who pulled you over that you paid Fred Brown to take the driving class and test so, really, the ticket should be written out to them.
- If your Safety Consultant is present when you meet with OSHA, you must be the one answering the questions. Never, EVER, let your consultant argue that a standard was incorrectly applied with the CoSHO.
- This happened to me and their consultant would not let it go, even after I cited the scope and explained how it applied. After 15 minutes I turned to the owner and continued the meeting as if the consultant was not there. Another CoSHO might not be as patient.
- Always read, and approve, any programs or documents a consultant brings in for your workplace before accepting them.
- One elementary school had a Hazwopper program which stated they were a Small Quantity hazardous waste generator. It also stated the building custodian had taken a 40 hour Hazwopper course. Neither was true.
- One University allowed their consultant to hand me paperwork that said their asbestos abatement worksite had all the boxes checked off for compliance, including specialized air cleaning equipment, and that this had been observed by the consulting firm's employee on Wednesday morning. This was after the employer told me that the work had been completed and the construction crew had entered and began working on the space Tuesday afternoon. This meant that required paperwork, inspections, and safe guards may, or may not have been in place when the complainant said they were exposed to asbestos.
- Always have at least one other person with you during the inspection. They can take notes, run for documentation, find an employee for the CoSHO to ask questions (usually they will approach an employee at random). You need to concentrate on making the process as smooth, and therefore brief, as possible for the CoSHO.
- Never offer the CoSHO anything of monetary value. If you get a drink from a vending machine, you can offer to give them change for a dollar. If you get a drink from the fridge it’s usually OK to ask if they would like one.
The reason Compliance Safety and Health Officers arrive unannounced is that they need to see how safety is on a normal workday. Compliance Officers know an inspection is unexpected, inconvenient, and unwelcome and most will work with you to create a cooperative relationship.
Simple Safety Coach helps you keep your information and data organized and easily accessible. This lets you focus on making the visit as smooth as possible. Schedule a Demo today and see how we can assist with your safety operations and safety culture!