Inspectors usually arrive without advance warning during regular working hours. After identifying themselves to the employer and explaining the nature and scope of the inspection, they will ask to see records, machines, equipment, and hazardous materials. They can also privately question any employer or employee.
What can employers expect on-site when an OSHA inspector calls? Here is what is likely:
Records review
Review of the OSHA 300 form and supplementary forms including possible workers’ compensation claim forms and employee medical histories. Note: Stores qualify for a partial exemption due to its low hazard industry code.
Personal Protective Equipment (PPE)
The use of PPE at the facility, the training of employees to wear that equipment, and the enforcement of its use on the job.
HazCom check
To ensure that the employer has an effective hazard communication program, the inspector will conduct employee interviews and document their responses. During a brief tour of the facility the compliance officer will confirm:
- a written hazard communication program does in fact exist
- the inventory of hazardous chemicals used at the site
- the existence and availability of material safety data sheets (MSDSs) or (SDS) safety data sheets in the work area
- the correct labeling of in-plant containers and containers received from suppliers
Particular attention will be given to the effectiveness of required training, using the employee interviews as a guide.
Overall safety and health program
The employer’s overall safety and health program, as well as other specific programs (emergency preparedness, MHE Training, etc.), will be reviewed. For example, a respiratory program, if required, and other personal protective equipment programs may be evaluated.
High hazard check
The location tour shall focus on high hazard areas of the facility including, but not limited to, the following:
- Maintenance Area
- Battery Charging Area
- Elevated Work Areas
- Receiving /Loading Dock
Knowing your rights and managing OSHA inspections effectively, you minimize regulatory compliance issues or liabilities that could arise.