OSHA Inspection Tips
By Susen Trail | 08/01/2019
The following tips are from 16 years in OSHA standard enforcement/consultation:
- Identify who should be notified when an OSHA officer shows up, never leave it to chance who presents your safety culture. Set up policy and procedure to get the officer to your designated person ASAP.
- Treat the enforcement officer's time as if it were gold! It is and it's your gold. For example, my second visit for an asbestos exposure complaint inspection was set for 10AM. The location was over 2 hours from my office. I was told to cool my heels for 4 hours. So, with the Safety Manager's permission, I met with the complainant and, during the tour of the site, found about 30 additional violations.
- Always have proof you are implementing your safety programs. If you have excellent compliance and therefore no written corrections on file that is Great! But write up some "attaboys" to show that rules are implemented.
- Never leave the enforcement officer alone with an employee unless specifically asked to do so. I've asked employees to show me where the SDS are kept and gotten more than a few blank stares. The Safety Manager rephrases the question, the right answer and a relieved employee result.
- Never volunteer information. Enforcement officers are curious as cats. That's why we stay in the job. If you give us a thread we just have to chase it to the other end.
- Never lie. If you can't find something tell the officer and estimate how soon you will be able to get the document or sampling results to them. Preferably the same day.
You MUST set up your occupational safety documentation so that nothing goes missing during the change over to a new Safety Manager. This also prevents dropped 'balls'. I'd say that 80% of the school districts I inspected had a former chemistry teacher listed as the Chemical Hygiene Officer. When they retired, no one took up the slack.
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