With more than 8 million worksites around the nation, OSHA can’t reach every worksite for an inspection. But for the more than 100,000 inspections OSHA does conduct each year, normally no advance notice is given. Knowing this, what should you do to fully prepare so that you can be ready? We sat down with Dan Burke, a seasoned employment law professional at Graydon Head & Ritchey LLP, to talk about this and much more when it comes to what leaders should know about OSHA inspection readiness. Founded in 1871, Graydon is a law firm that focuses on providing exceptional service and expertise to clients in almost every area of law. Located in Graydon’s Cincinnati, Ohio office, Burke represents and counsels clients on a wide variety of employment, education, senior care, and workplace health and safety issues. Burke has represented clients before state and federal agencies, including the Equal Employment Opportunity Commission, Ohio Civil Rights Commission, Ohio Bureau of Workers’ Compensation, Industrial Commission of Ohio, and the Occupational Safety & Health Administration, as well as federal and state trial and appellate courts. He also chairs the Firm’s Labor & Employment group. Here are 6 ways you can become more prepared for an OSHA inspection:
1. Know your key point(s) of contact.
Knowing who your company representative is before any inspection is critical to any successful OSHA inspection, explains Burke. First and foremost, it cuts down on figuring out who that person will be if and when OSHA stops by. You’ll choose that person carefully, explains Burke, since you want that person to be able to handle the inspector professionally, be aware and informed on what actions will be taking place, and you want the person to represent the company in the right light in general. Burke can’t emphasize enough how important it is to choose this person carefully; after all, this is the person who will be responding to requests by the OSHA inspector and they will also conduct tasks such as letting company workers know their rights if they are interviewed by the inspector. “That’s one of the first and key ways to be prepared before OSHA arrives,” adds Burke.
2. Create an OSHA response team.
To be totally ready for an OSHA inspection, consider creating an OSHA response team, adds Burke. This can consist of two to three people, for example. Ideally it’s a group of people who are eager to be a part of the team and are well-versed in standards and compliance at your company. “It’s also a good idea to have that team ready because you know one of them may not be there on the day OSHA shows up, and it’s important that you be able to reach somebody that is prepared for how to deal with an OSHA inspector,” explains Burke.
3. Keep it courteous and professional.
A major mistake some companies make is to treat the OSHA inspector poorly, or to be rude to the person upon his or her arrival. This can immediately backfire, explains Burke. You may assume your workers would maintain an upbeat, professional demeanor, but make sure workers know the importance of their manners during the entire process. After all, that’s something you can control. After you see the officer’s ID (which you’ll want to be sure is documented), then you’ll most likely be handing over certain documents to him/her. Don’t be afraid to tactfully and courteously ask for his/her to put on protective gear, too; after all, it just shows you know the importance of having everyone on site be protected.
4. Be ready to provide the right information.
Make sure your company representative and others on your OSHA response team know how to answer or provide the following, at minimum:
- Information about the facility including number of employees/workers
- Names of managers/supervisors in charge
- Contact information for those parties
- Injury and illness logs
“Having these key documents that you know they will ask for in any inspection up-to-date is important. And, make sure you know where to locate them quickly,” adds Burke. It’s a great way to show OSHA your organization is prepared, organized, up-to-date, and in compliance.
5. Know how you’d like the walk-around to proceed.
The OSHA inspector can take any path he or she may want, but be prepared with a path that you would ask him/her to take. Put simply, they might want to inspect a piece of machinery or a certain part of your plant. With that in mind, you want to be sure to pick the path carefully in order to focus the inspector on what they’ve asked to see. That way, along the inspection, you’ll be as equipped as possible to answer questions.
6. Accompany the inspector.
“Make sure you’re shadowing the inspector. One, so they don’t wander from the area they’ve asked to see, and two, if they take a picture or a video of something, you should obtain the exact same picture or video with a company camera,” explains Burke. You want to take the same photos (or videos), but also make note of workplaces inspected and also document the workers and/or managers who were interviewed. That way, if there is ever a dispute or disagreement of some kind, you have documentation on exactly what took place, involving who or what, on what day. Since some inspections can carry over to multiple days or even weeks, you can see how having a copy of information for your own purposes is important. These are the basics on how to prepare for an OSHA inspection. In our next post with Burke, we’ll cover some of the top ways best-in-class companies also prepare for an OSHA inspection.
Keep Sound Records
Do you have your workers’ comp, leading indicators, safety and other general liability and insurance reports easily accessible and available? This can not only help make the process effective, but it can also ensure you’re ready when OSHA arrives. iReportSource will keep all of your proactive and reactive activities all in one place making management and collaboration for your team easy and all records accessible when you need them quickly! Learn more about how iReport can help you stay OSHA compliant, increase your business intelligence, and lower your risk: request more information today.