The 411 on Managing OSHA Inspections
OSHA Inspections: Be Prepared
Virtually every manufacturing and recycling operation is subject to an OSHA inspection. Some may fear the inspection process and may not know what to expect. The reason an employer will receive an OSHA inspection may vary.
Reasons for an OSHA Inspection
OSHA doesn’t have enough personnel to effectively inspect all businesses that are under their jurisdiction. Therefore, a basis for priority has been established to help focus the limited resources OSHA has. Below are the most common reasons why OSHA might conduct an inspection at your operation:
Fatality Inspection– OSHA will investigate all workplace fatalities. This is a priority for their inspections. The scope of the inspection will generally be limited to the operation where the fatality occurred. (Reminder - OSHA must be contacted within 8 hours if a fatality occurs.)
Employee Complaint– Employees have the right to contact OSHA to make a complaint for issues related to workplace safety and health. The complaints are taken seriously and will lead to an inspection if the complaint is credible. The most effective way to avoid an employee complaint is to have a well implemented safety and health program and to maintain good communication with employees related to safety issues.
Referral– Other entities may report a workplace safety and health issue to OSHA which may result in an inspection. In many cases, an ambulance company who responds to a serious injury at a workplace will report the injury to the local OSHA office. Other entities such as building inspectors, fire department and police departments, may report safety issues they observe to OSHA.
Scheduled– OSHA inspections may be “scheduled” based on local emphasis programs. Some OSHA jurisdictions have informally focused on recycling operations based on potential for serious injury.
Focus Items During an OSHA Inspection
During an OSHA inspection, the compliance officer will communicate the reason for the inspection and what issues or operations they plan to focus on. Some of the more common issues that will be evaluated include:
- Administrative Safety
Key areas include written safety policies, accident investigation, OSHA 300 logs and documentation of safety training.
- Machine Guarding
Any piece of equipment with moving parts is required to have all parts protected to prevent employee injury.
- Heavy Equipment Operation
Forklift drivers must be licensed and other operating equipment must have appropriate employee safeguards in place to avoid employee/equipment accidents.
- Lockout and Tagout Programs
OSHA may investigate written policies, employee training and documentation of applying the program.
- Personal Protective Equipment (PPE)
Proper use of PPE will be evaluated by OSHA. Employers who have completed a PPE hazard assessment will be in a better position to avoid citations.
- Industrial Hygiene Issues
Many operations have exposures requiring completion of IH testing for air quality and noise levels. If OSHA determines exposures exist, they may return to complete IH testing as part of their investigation.
The best defense against OSHA citations is to have an effective safety program that is well implemented. A successful program will address the vast majority of OSHA standards and will also improve safety at your facility.
- Controlling Hazardous Energy: Lockout and Tagout Programs
- OSHA's Top 10 Cited Standards for Scrap and Waste Materials Companies
- Four OSHA Regulations You Should Know for Machine Guarding
- Safety E-Book
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