How to Prepare for an OSHA Inspection
An inspection by OSHA, whether announced or unannounced, can be a cause for much stress and concern. This stress is often caused by fear of the unknown and the implications to your enterprise from any violations. But does it have to be so?
Wouldn’t it be advantageous if you had a data-driven process with easy access to all key data that OSHA will need? What if your enterprise is proactive in its approach to health and safety so that an OSHA inspection is just another day in the office?
The key here is simple. If you are well-prepared for an OSHA inspection anytime, there is no need to scramble for information right before an inspection. In this blog, we share a few best practices to help you prepare for an OSHA Inspection.
Nature of OSHA Inspections
In the United States, workplace safety is governed by “OSHA”, the Occupational Safety and Health Administration of the United States Department of Labor. It sets and enforces standards and also provides training, outreach, education, and assistance. To ensure compliance, especially in high-hazard companies and industries, OSHA conducts programmed (or planned) and unprogrammed (or unplanned) inspections.
While programmed inspections are routinely conducted to ensure risk mitigation of employee and environmental safety, unplanned inspections are triggered by accidents leading to death or severe injuries. Any complaint from employees can also cause an inspection to be conducted suddenly, without prior intimation.
OSHA has jurisdiction over approximately 8 million employers and 130 million workers and only has about 2,000 inspectors. The good news is that unplanned inspections are rare and occur only when absolutely necessary due to the limited number of resources that OSHA has at its disposal. The bad news is that if there is an unplanned visit, then there has been a deviation and you may be facing an action.
Triggers for OSHA Inspections
To optimally use its limited resources, OSHA has established six main priorities for conducting inspections and investigations:
- Imminent danger situations
- Fatalities and catastrophes
- Complaints registered by employees
- Referrals from other agencies
- Follow-up inspections for worksites previously found to be in violation of OSHA health and safety standards
- Planned or programmed investigations of targeted industries or areas
Even if your workplace does not fall into any of the above categories, having a plan for a possible OSHA inspection is important because meeting regulatory standards is also about employee safety and health.
Conversely, if you are proactive in ensuring a safe workplace, then the likelihood of having an inspection is very low.
The OSHA Inspection Process
An OSHA inspection is very process-oriented and typically involves the inspector:
- Presenting his or her credentials at the opening conference
- Explaining the purpose of the visit
- Inspecting the site
- Sharing his/her findings and any deviations at the closing conference
Though the process is simple, the inspection may be intimidating to you and your employees. Know the process and train your employees for the inspection to avoid unnecessary anxiety.
- Since OSHA’s focus is injury and illness prevention at the workplace, put in place an ‘I2P2’ – the injury and illness prevention program. This helps in delineating the hazards employees face, and the ways in which the business ensures their protection. A person is assigned to take ownership and accountability for the program.
- Documents are an essential part of OSHA inspections as well as being a critical component of any successful safety program. You will be expected to share your I2P2 plans, records of safety training, medical surveillance records and OSHA logs at the opening conference. There will be other mandatory documents needed such as your communications to the employees regarding potential hazards and the safety measures for different aspects of your business. Having the records ready will make the inspection process smoother and quicker.
- Let the inspectors do their job, be it inspecting the workplace or interviewing employees. Neither interfere with the process nor volunteer unnecessary information. Have the person accountable for safety available, train them how to respond to the inspectors, and instruct them to be ready with the required documents. Also, have a backup in case the person is on leave or absent.
- You may have reasons for deviating from the OSHA standard such as limited resources. You can apply for a compliance exception or variance. Your local OSHA office can guide you about this option.
- Since OSHA standards are very demanding, you may find it challenging to do it on your own. OSHA offers free compliance assistance programs such as OSHCON for identifying and correcting violations without being levied a fine; and VPP that allows employers to enroll in OSHA’s voluntary protection program and be exempted from programmed inspections.
If the inspection reveals any potential hazards or violations, ensure prompt corrective action as well as preventive action to avoid repeat occurrences.
Periodic internal audits will help you prepare for the inspections. You can review documents; ensure they are up to date and that your employees are aware of their roles and responsibilities during an inspection. All required safety training should be administered and recorded. During the audits, inspect the facility to identify violations and variances to correct them. This way you are not only ready for an inspection but can minimize the need for one.
Automating Safety Requirements
Being proactive with safety management. Complying with the OSHA standards. Being prepared with necessary documents. Periodically conducting audits and having CAPA. An organization can find it overwhelming to keep track of so many requirements while continuing to conduct business activities. An automated EHS system, such as the one from ComplianceQuest, can automate your EHS initiatives and keep you inspection-ready. It is a cloud-based solution built on SalesForce.com, and it can reduce the need for inspections due to the development of a safety culture in the organization.
ComplianceQuest’s EHS solution includes the following features:
- Health and Safety – Centralize your incident data, near misses and safety observations. You can perform investigations and implement corrective actions. Built-in analytics and dashboards help to detect hazardous events and prevent accidents. (learn more)
- Risk Management – An integral part of CQ’s end-to-end Enterprise Quality and Safety Management System, it can help businesses can provide a complete and accurate picture of the risk landscape across product lines, business processes, and business units, and comply with ISO 9001:2015 risk management requirements. (learn more)
- Supplier Management – The CQ Safety solution can also help boost a safety culture in the partner organizations through an integrated framework. (learn more)
- Training– Ensuring timely and periodic training in safety practices. (learn more)
The EHS solution is integrated with CQ’s enterprise-wide quality management system and also automates audits, document management, equipment management, inspection management, CAPA, complaints handling, and so on.
If you would like to improve the safety culture in your organization and be better prepared for OSHA inspections, contact us here: https://www.compliancequest.com/contact-us/