The very thought of unexpected government scrutiny is enough to make most of us break into a cold sweat. When combined with potentially sizable penalties, understandably, an unannounced OSHA inspection can be a source of serious concern.
If OSHA comes knocking at your door, you can reduce pre-inspection jitters by being well-prepared.
Here are some tips that can help you prepare for the process:
- Make a Good First Impression: Keep a well-maintained building. Check your parking lot for obvious signs of walking and working surface hazards, such as crumbling steps, missing handrails or trip, slip or fall hazards. Make sure signage is clear. Consider any obvious hazards in plain view outside the facility, including workers’ activities. In one inspection I mediated, the workers were doing annual repairs at the exact time the inspector arrived. The timing couldn’t be worse, as the workers were on the roof, with no fall protection. Let us just say that was one of the more detailed inspections I’ve encountered…
- Pay Attention to Detail: Appropriately display your OSHA poster and emergency evacuation/shelter procedures. Between February 1st and April 30th of each year, make certain your 300A is posted in an area visible to workers and is signed. (One of my clients received a citation for an unsigned, but posted, 300A.) Likewise, make it daily practice to check emergency exits, electrical breakers and fire extinguishers. Blocked fire extinguishers or breaker panels, unlit exit signs or cluttered exit routes can be factors that rack up penalties and show the inspector your attention to common safety hazards is lacking.
- Stay Current: Keeping accurate records, maintaining adequate written programs and conducting routine hazard analysis are critical toward keeping workers safe and minimizing OSHA penalties. Document! Document! Document! Stay current on every type of documentation possible. Make a training calendar that shows when to conduct annual re-trainings. Examine written programs consistently throughout the year for changes, new hazards or novel legislation that may make your programs ineffective or obsolete. If your written programs are gathering dust on the shelf or if no changes have been made in a decade, OSHA WILL notice this and it weighs heavily on your citation factors.
- Investigate and Correct: Always conduct accident and near miss investigations which include documented corrections and follow-ups. OSHA understands that accidents and injuries occasionally happen. However, they are NOT pleased with employers who allow these types of incidents to happen without corrections. Too many accidents, injuries or near misses that are uncorrected (or one serious event) and you may be viewed by OSHA as “willfully” exposing employees to hazards. Willful citations result in significantly higher penalties and other unfortunate ramifications.
- Keep 300 Logs Handy: To avoid looking like a deer in headlights if an inspection occurs, keep at least 3 to 5 years of 300 Logs handy in an easily accessible place. In a separate file, keep copies of all corrections made following these workplace injuries or illnesses and separate copies of the actual injury reports in the employee’s files. OSHA will review your 300 Logs and may ask for the other supporting information as well. Inspectors tend to view employers more favorably when these items are very accessible and the corrections are well documented. And I can’t stress enough– make sure your 300 Logs are accurate. Falsely reporting or underreporting is fraud and is penalized significantly.