• Arrival of the Compliance Officer:

 A designated individual from the company should greet the compliance officer and check the credentials. In rare cases when a search warrant seems necessary or prudent, verify that the search warrant is valid. If a management representative is not on site, the inspector is responsible for attempting to contact that person and to request his or her presence. If a management representative is unavailable within about an hour, the inspector can begin the inspection without a management representative present.

• Opening Discussion or Conference:

 This conference is your chance to get more information regarding the inspection. Each inspector most likely will do things a little differently however the general outline for an inspection is as follows:

The compliance officer should explain the nature of the visit and the scope of the inspection along with standards that apply. If your inspection is a result of an employee grievance or complaint, you have a right to see a copy of the complaint. If this is the case the compliance officer will most likely not reveal the name of the employee who filed the complaint.

An authorized manager or representative is also given the opportunity to attend the opening discussion or conference and to accompany the on site compliance officer during his or her inspection. An employee union or a plant safety committee (in the absence of a union) are allowed to designate an authorized employee. In a case where neither employee group exists, the employee representative may be selected by the plant employees or the compliance officer will decide if any employee effectively represents the interests of the other employees. The employer will not be allowed to select the employee for the OSHA walk through.

The S&H Act does not require an employee representative at each inspection. If there is no authorized employee representative the compliance officer must consult with a reasonable amount of workers concerning health and safety issues in the workplace. These consultations may be (and usually are) held privately.

The on site OSHA compliance officer might want to see reports of work-related injuries and/or accidents recorded in your OSHA log. Be prepared to show the compliance inspector your HAZCOM, or hazard communication program, LOTO, or lockout/tagout program, a general safety program and other records relating to the safety of your employees.

• Walk Through Inspection:

The compliance officer will decide the route and length of your safety inspection. While conversing with your employees, the compliance officer should make a genuine effort to minimize any interruptions with your employees during the walk through. The compliance officer will closely monitor conditions, speak with workers and take photos for record purposes. It is highly advised that you bring a camera and notebook along for the walk through. Be sure to take any pictures of the exact items in which the compliance officer takes and also make notations of any items that they take as well. If you are not certain of what the officer is making notes of, you may ask the officer what their notes were about. The officer may take instrument readings if necessary and examine records.

An OSHA inspection is an evidence gathering process. Prepare to document the entire inspection.

• Closing Conference:

At the closing discussion or conference, the OSHA compliance officer and the employee representative will discuss all unsafe conditions observed during the inspection with the employer. The inspector will clearly indicate all violations for which a safety citation can be issued. At this point in time, the employer is made aware of appeal rights by the OSHA Inspector. The inspector will not indicate any proposed penalties due to the fact that only the OSHA area director is empowered to issue these penalties.

As the owner, manager or employer, you should be given a chance to discuss these violations so that you may present your side of the argument or case. It may be in your best interest to produce documentation of compliance efforts and provide information that may help OSHA decide the amount of time may be necessary to abate any alleged violations.

At the closing discussion or conference, the OSHA compliance officer may decide to hold the conference with the employees or their representative in order to discuss matters of direct interest to employees.

• Post Inspection:

Make certain that you gather any notations of the opening discussion, walk through, and closing discussion in a file. Also, include any pictures that were taken as well. Be sure to follow up with any employees who were interviewed by the OSHA compliance officer. If the employee has signed a statement, you are entitled to receive a copy of that statement for your file.

• Conclusion:

Above everything, remember that the OSHA compliance officer was at your facility because there is a question (whether unfounded or not) about the well being and safety of your employees. The level of cooperation between yourself and the OSHA compliance officer will result in a safe working environment for your employees. The overall objective is to remedy any unsafe working conditions with minimal or no penalties/citations issued to your company.

Read this article on What To Do When OSHA Comes