The threat of an Occupational Safety and Health Administration (OSHA) inspection may seem inevitable. In reality, the potential is pretty low. Each year, state and federal agencies conduct only about 100,000 job site inspections. However, creating a safe work environment is still very important.
Studying the most frequently cited overall violations, as well as those found during inspections of electrical contractor job sites, can provide insight into common problem areas. The table at right shows the top five violations OSHA cited in fiscal year 2017 for all businesses and the top five issued to ECs.
Most inspections occur with no advance notice. As a result, employers should have a plan in place and be familiar with what to do when an OSHA inspector arrives. A plan will help the process go smoothly and likely result in fewer violations.
There are five parts to an inspection: the inspector’s arrival and display of credentials, an opening conference, the walk-around or site inspection, employee interviews, and a closing conference.
Whether dressed casually or formally, inspectors must identify themselves. If they don’t provide ID, ask for it to verify they are who they say they are. If there is any uncertainty, contact the local OSHA office to ensure they are legitimate.
Employees and employers are entitled to have a designated representative present throughout. Typically, at larger organized sites, union labor contracts dictate this. If the appropriate parties are not available when an inspector arrives, you may be able to reschedule, or the inspector will wait a reasonable time for the representative to show up. This is not a hard-and-fast rule, but the employer must be represented. It’s advisable to have a backup plan just in case.
Inspectors often go to job sites in response to an incident or complaint. In such a scenario, they are interested in seeing a specific area only, and it is common practice to escort the inspector to the referenced location and limit their access to the area of concern. The inspector’s escorts should ask the scope of the inspection and the reason for the visit. If the inspection is the result of a complaint, the employer has a right to request a copy of it.
Often, the inspector will ask for OSHA logs and safety program information such as injury and illness records, hazard communication program materials, and emergency preparedness and evacuation procedures. Employers are required by law to keep and maintain electronic and paper records. The records should be available should an inspector wish to see them. Having inaccurate or disorganized records can result in citations and a more thorough review of the work site. Provide this documentation only if the inspector requests it.
Employees should answer questions honestly without volunteering information. If they do not know the answer to a question, they should respond by saying something to the effect of, “I’ll have to check and get back to you on that.” Employees also have the right to refuse to respond, request the presence of management or a representative before speaking, or ask for a private discussion with the inspector.
Full, thorough inspections typically occur only when all of the following criteria are met: an employee complaint is received, the business is in an industry with a high injury rate, the employer has a lost workday rate at or above the national average, and OSHA has not carried out a complete safety inspection during the last two years.
Practicing good housekeeping is important, too. A messy work site can result in additional hazards and suggest recklessness.
Finally, be courteous! This should be a no-brainer, but being polite can result in a less critical inspector.