Aside from an accident or serious injury on site, an unannounced Occupational Safety and Health Administration (OSHA) inspection is probably the safety-related event that companies dread most. Certain injuries—inpatient hospitalization, amputation, loss of an eye—must be reported to OSHA and will automatically trigger an inspection. But even non-reportable incidents can lead to a visit if the treating physician believes the circumstances may suggest weak safety practices.
Because OSHA regulations touch nearly every aspect of an Environmental, Health, & Safety (EHS) program, it’s natural to assume that an inspection means a full, top to bottom scrutiny of the entire program. In reality, inspectors usually focus more narrowly on the incident that brought them there and the policies directly connected to it.
OSHA has limited resources and oversees a vast number of employers and workplaces, so their inspections tend to have the goal of efficiently determining if an incident resulted from gaps in a facility’s safety program. Unless they observe something blatantly unsafe—like lack of Personal Protective Equipment (PPE)—they generally won’t expand their scope. Most inspectors also do not have laboratory backgrounds, which naturally focuses their attention on what they can clearly evaluate.
Inspection Process
A typical inspection starts with an opening meeting where the inspectors explain why they are there and what they will look at. Anyone whose job function bears on the incident should be present, such as the EHS Manager, Chemical Hygiene Officer, or Biosafety Officer as appropriate, and an executive level employee who oversees safety. Companies may also wish to involve someone from their legal team. Including someone to perform administrative tasks, such as taking notes, gathering requested documents, and accompanying the team on the walkthrough to keep a record of what was inspected and to take pictures, is highly recommended.
Inspectors will then want to see where the incident occurred; make sure they are provided with any personal protective equipment (PPE) required in that area. If the inspectors take pictures, try to take the same photos to refer to when following up. They will ask about policies and procedures relevant to the incident: who sets them, who enforces them, and whether they were followed. Additional questions that may be asked include:
- Was the person wearing the necessary PPE, and who determined what was required?
- Was an eyewash and/or emergency shower close enough?
- Was a fume hood or biosafety cabinet available?
- Were Safety Data Sheets (SDSs) and safety manuals easy to access?
A records review is a standard part of the process. Training records and training materials will indicate how well employees are prepared, so these will typically be requested. If the company keeps OSHA injury and illness logs (it may be exempt), they may ask to see several years of them. Safety committee meeting minutes that describe any follow-up actions or policy changes can help demonstrate an organization’s good faith commitment to preventing repeat incidents.
Only provide what is specifically requested during any inspection and keep copies of any documents provided as part of the inspection record. Never give inspectors access to files, logbooks, or databases. Volunteering additional information can complicate the discussion and open the door to unrelated findings. The same goes for casual dialogue during the tour of the facility.
Inspectors will likely conduct private interviews with the person or persons immediately involved in the incident. They may also ask to speak with a more experienced person who performs similar work.
A closeout session is not typical, but inspectors may agree to one if requested. Before leaving, they will usually give a rough idea of when to expect their written report and verify that they have the appropriate recipient for it.
Safety Partners can provide support before, during, and after an OSHA inspection. We can also develop and implement your safety programs, perform employee training, and oversee workplace health and safety assessments—contact us!
This blog was written by Christopher Neal, Safety Partners’ Quality, Research, and Training Specialist.
