Use the guidelines below to help prepare for an OSHA inspection.
Grant Davis GDI Cares More
- GDI Safety Programs, OSHA Compliance
The best bet is to call GDI right away, and ask your GDI broker to help you get ready. If your Mod is over 150 you have a visit coming.
GDI brokers are trained on OSHA comliance and ready to help. Below is just a brief outline of what to expect and what to do. GDI cares about your employees safety, and GDI cares about your companies compliance. This is a free service for our clients.
What triggers an OSHA inspection?
An OSHA inspection can be triggered by any of the following:
- Planned inspection
- National/local emphasis program (lead, amputations, etc.)
- Site specific targeting program (high incident rate sites)
- Follow-up on a previous inspection
- Imminent danger
What comprises an OSHA inspection?
- OSHA log accuracy (from the last 5 years)
- 101/301 or first report of injury for every log entry
- Medical surveillance (hearing tests, respiratory, etc.)
- MSDS books/sheets
- Written safety compliance programs (HazComm, lockout/tagout, emergency procedures, etc.)
- Development of the written program
- Execution of the programs
Employee training (orientation, refresher, attendance records, subject matter, etc.)
- Identify physical hazards
- Observe employee unsafe behavior
- Evaluate level of non-compliance with OSHA standards
- Labor representative
- Rank and file
- Provide a room with privacy for the inspector.
- Examine the inspector’s credentials.
- Ask for the purpose of the inspection (complaint, etc.).
- Determine how you will handle the inspection.
What should I do if OSHA wants to inspect my worksite?
- Buy time: Require the inspector to leave and obtain a warrant, or ask the inspector to come back the next day because you are busy (depending on how much time you need).
- Let the inspector in to proceed with the inspection, accompanied by appropriate personnel.
- Inform appropriate production personnel (managers, supervisors) of the imminent inspection; advise them to quickly tour their areas and make “last minute” improvements (e.g. housekeeping, PPE, etc.).
- Someone who is familiar with your written programs, as well as the facility, should accompany the inspector at all times to ensure questions can be answered appropriately.
- If the inspector identifies any “quick fix” items, have them taken care of immediately, or at least by the time the inspector returns again.
- Take “before” and “after” photographs of every improvement made.
- If the inspector takes photographs or video, consider doing the same concurrently.
- If the inspector conducts noise or air monitoring, consider doing the same concurrently.
- Take good notes during the post-inspection conference; the inspector’s comments are likely to be items that might show up in citations.
What are OSHA’s violation classifications?
- Willful violation (maximum $70,000)
- Repeat violation (maximum $70,000)
- Serious violation (maximum $7,000)
- Other than serious violation (maximum $7,000, can be $0.00)
Why might OSHA write a citation and assign a $0.00 penalty?
OSHA often assigns a $0.00 penalty in order to write a large number of citations without it being unrealistically expensive for you. However, this is typically only done one time; if OSHA finds the same violations in the future, it may cite you for a “willful” or “repeat” violation and assign a penalty up to $70,000.
Be sure to start with a clean slate. All violations from previous inspections should be cleared, or you may be assigned large penalties.
What should I do if I receive citations following an OSHA inspection?
- Pay the citations.
- OSHA may offer a reduction in the penalty if it feels the inspection otherwise went well; it will ask you to agree to pay the penalty early in order to pay the discounted penalty.
- If you strongly disagree with one or more citations, send OSHA a letter of “notice to contest” within 15 days of the inspection; prepare to go to court.
- Use the “informal conference”:
- This is one of the most common responses.
- Meet with the OSHA area director within 15 days of receiving the citations.
- It enables you to challenge the citations and penalties without going to court.
- Regardless of the outcome, you give up your right to officially contest your citations.
- You can make your case to eliminate the citation altogether, reduce the severity of the citation classification, reduce the penalty amount, or revise something about the abatement (time or content).
All this can sound like a lot. But GDI cares about your business and is ablel to help. Just call any GDI broker. 888-991-2929
- Grant Davis President GDI Insurance