What To Expect During an OSHA Facility Audit
An OSHA facility audit, also known as an inspection, by OSHA is broken up into four different sections. The inspector’s credentials, the opening conference, the walkthrough, and the closing conference. The employer or the employer’s representative is involved in every step of the process, but it’s still nerve-racking if you’ve never been through an inspection before. So, we’ve outlined the process below to ease your worries.
1. Inspector’s Credentials
When an OSHA compliance officer arrives at your business, they will display their credentials and ask to meet with a the business’s representative. You have every right as a business to ask to see the OSHA compliance officer’s credentials, and you should always ask. You can call your nearest federal or state OSHA office to verify those compliance credentials. It’s important to take advantage of this step because someone could impersonate an OSHA officer to gain access to your establishment, to learn their way around it, and for many other reasons that could threaten the safety of your business. Always check the credentials and verify that information with an OSHA office.
2. Opening Conference
The audit or inspection begins with an opening conference in which the compliance officer explains why your establishment was selected for an audit and what the scope of the inspection will be. It’s also at this time that they will check to see if you participate in a program that renders you exempt from the inspection. In which case, they audit will be terminated there. A program that allows you an exemption from an OSHA inspection would be the OSHA Star program (link: http://www.opexcel.com/osha-star-voluntary-protection-program/) which you can read more about on our website.
Also, during the opening conference, an employee representative will be chosen to accompany the compliance officer during the inspection. If you choose not to have a representative walk with the compliance officer, then the officer will consult with “a reasonable number of employees concerning safety and health matters in the workplace.”1 But it’s not a requirement to have an authorized employee accompany the compliance officer.
Next, the compliance officer will then begin the inspection, walking the establishment and inspecting the work areas. The route and duration of the inspection are determined by the compliance officer, and they attempt to follow that route causing the least work interruptions possible. The compliance officer, during the walkthrough, will:
- observe safety and health conditions and practices;
- consult with employees privately, if necessary;
- takes photos, videotapes, and instrument readings;
- examines records;
- collects air samples;
- measures noise levels;
- surveys existing engineering controls;
- monitors employee exposure to toxic fumes, gases, and dusts.
Even if your establishment requires inspection because of a particular incident, the compliance officer will likely still walk through the entire building. Of they may even plan to only inspect a small portion, but if they find a violation they may choose to expand that inspection.
The compliance officer will also ask to see your records and check that you’re following the posting requirements. They will check:
- records of death, injuries, and illnesses;
- that you have a copy of the required documents from the OSHA form;
- that you have the OSHA workplace poster prominently posted (pictured above);
- a copy of your Hazard Communication Program.
Throughout the inspection, the compliance officer will point out any violations or unsafe conditions to the authorized employee, they will also offer advice on how to correct the problem. Some can be corrected immediately, and it’s always good to correct them on the spot, they take note of that and possibly could reduce the penalties!
4. Closing Conference
The closing conference follows the inspection and involves the compliance officer, the “employer, employee, and/or the employee’s representative”1. During this conference, the compliance officer provides all parties involved with a copy of Employer’s Rights and Responsibilities Following an OSHA Inspection. The compliance officer uses that copy as a basis for the discussion, where she/he will recap the inspection and point out any conditions that threaten the safety or health of employees for which they may receive a citation or penalty, but they also reiterate the appeal process for the employer.
The compliance officer will then report his/her findings to the Area Director, who will determine whether or not to issue citations or penalties proposed by the compliance officer.
If you have any questions about citations and penalties, check back in on the blog next month where we’ll go more into detail regarding the results of an inspection!
If you aren’t ready to go it alone on the inspection, give us a call at 877.266.1438. We’ll be with you every step of the way!
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