What would you do first? You can refuse to have a compliance officer come onto your work-site, but he will only return with a court order...... Not a good start for an OSHA inspection.
What you should do this at the beginning of the inspection
- Ask the Dept of Labor (DOL) compliance officer for identification
- Notify your foreman, project manager & safety director that the compliance officers is on the work-site
- The compliance officer should be escorted at all times during the inspection
There will be an opening conference which will include the purpose of the inspection and the type of inspection to be performed. The compliance officer may ask to review written safety programs, hazard communication program, training documents, OSHA 300 logs, etc.
Purpose of the Inspection
- Employee Complaint
- Planned
- Drive by
- Serious accident and / or injury
Type of Inspection
- Complaint
- Wall to Wall
- Emphasis program focused
The compliance officers will then perform a walk around inspection. The compliance officer may do the following while conducting the inspection.
- Take photos
- Video tape
- Examine job site conditions, job hazard exposures to employees and safety controls in place
- Interview employees, specifically competent person at the work-site
Your representative (project manager, safety director, or job foreman) should do the following
- Accompany the compliance officer on the inspection
- Limit access to specific location the compliance officer discussed in the opening conference
- Be truthful with the compliance officer
- Take thorough notes
- Identify safe practices to the compliance officer
- Correct violations immediately
- Inquire about results
Do not:
- Argue with compliance officer
- Discuss inspection with anyone other than your management
- Admit to any violations
Interviews
- The compliance officer may want to interview personnel
- The interview may include supervision and non-supervision employees
- Take notes of who was interviewed
Pre-closing Conference
The compliance officer may request certain information. Some of the requested information could include the following.
- Safety policies and programs
- Training records
- Information regarding equipment and machinery that was involved in the inspection
Violations found by the OSHA compliance officer will be discussed during the closing conference.
OSHA's website - http://www.osha.gov
OSHA has a Compliance Assistance Program, additional detail can be found using the following link. http://www.osha.gov/dcsp/compliance_assistance/index.html
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