This will provide a summary of
the O.S.H.A. inspection process and the procedures that should be followed by
all personnel during an inspection.
I-
UPON INSPECTION:
-
Notify management of the inspection
-
Ask compliance officer to wait until a management representative is present
[If this request is denied, the employee
representative should accompany the
Compliance officer.]
-
Ask to see identification from compliance officer
-
Ask what the purpose of the inspection is
-
If you have an active safety program
in place, ask to be considered for a Focused Inspection
II-
DO’S AND DONT’S:
Act as a professional and do not argue
with the Compliance office. Do not
answer any unasked questions or volunteer information.
A- DO:
-
Accompany the inspector at all times.
-
Take photographs of EVERYTHING the compliance officer photographs.
-
Immediately
correct ANY items noted as possible violations/citations
- Take detailed notes of the
inspection:
*
Who was interviewed
*
Items noted as violations
*
Comments made by compliance officer and others
-
Act as a professional at all times
-
Answer all questions truthfully (Not doing so is a federal offense.)
-
Have an employee to tour with you to correct items as needed
DON’T:
-
DON'T Allow the CO to walk on site unescorted
-
DON'T Argue with the Compliance Officer
-
DON'T Become angry
-
DON'T Admit that something is a violation
-
DON'T Give them documents that were not requested
-
DON'T Lie or mislead the CO.
-
DON'T Answer question based on your OPINION. (i.e.: Do you think this is unsafe?)
-
DON'T Volunteer information
-
DON'T Discuss your knowledge of a violation situation. You may convince the CO that it is a Willful
violation.
III-
FORMAT OF INSPECTION:
1-
Opening Conference:
The compliance officer will state the purpose of the inspection. Questions the management representative
should ask:
-
To see credentials of the compliance officer
-
The purpose of inspection
-
The SPECIFIC areas the officer plans to inspect.
2-
Walking inspection: The compliance officer will walk and
inspect the areas that are identified at the opening conference. The management representative should
accompany the officer during this process.
3-
Closing conference:
The compliance officer will report the items that were noted and may be
subject to a citation. Make sure you
identified all citations that were corrected immediately. The rights of the employer involved will also
be discussed at this point. The
management representative can ask how the alleged violations will be classified. (i.e.:
Willful, Serious, Other than Serious.)
V-
EMPLOYERS RIGHTS DURING AN INSPECTION:
1- Rights of the EMPLOYER:
Before the Inspection:
-
To see the inspectors Identification.
-
To have an opening conference.
-
To know the purpose of the inspection.
-
To receive a copy of the complaint causing the inspection.
-
To require an inspection warrant to conduct the inspection. (This
may not be advisable)
-
Time to consult your attorney if you should allow the inspection without a
warrant.
(Reasonable amount of time @ 1 hour.)
During the Inspection:
-
To accompany the inspector during the inspection.
-
To demand the inspection be done in a reasonable manner with respect to time
and manner.
-
To require the inspector to follow existing safety policies.
-
To decline to answer the inspectors questions.
(This may not be advisable)
-
To require that employees be interviewed at a time and place that will not
interfere with their work.
After the Inspection:
- To take a reasonable amount of time
to turn requested documents to the compliance officer.
-
To ask the compliance officer at the closing conference to classify the
possible violations as "willful,
serious, other than serious."
The Compliance Officer should discuss
your rights with you at the closing conference and leave you with a small red
pamphlet that will list these items.
It is
your responsibility to exercise our rights!
POSSIBLE
AREAS OF FOCUS DURING AND INSPECTION
**This list does not cover all possible items, but is a good
starting point
Correct
State of Illinois posters – Illinois right to know
Life safety code issues – Marked exits, blocked exits, emergency
lighting (If employees are there after dark) clear isle ways
Fire protection – Proper extinguishers, enough for the SQ FT
of building, Travel Distances (Standard - shoot for 1/3000 sqft, no more than
50’ of travel distance) mark extinguisher locations, distances are closer when
flammable/combustible liquids are present (25’)
MSDS – Material Safety Data Sheets – Must be available for everything;
employees must be able to know where they are and must have free access to
them.
Flammable/Combustible storage – Amounts (Large amounts may need to be
sprinklered), Storage cabinets, Proper
containers – Gas, kerosene, diesel steel safety cans with spark arrestor and
self closing lid, Bulk tanks double walled or diked (catch basin) for
spills/leaks
Flammable/combustible liquid transfer – Use a bonding wire to transfer liquids from
one container to another
Electrical – No exposed/damaged outlets, no damaged
extension cords – missing ground pins, excessive repairs (3 per 25’), exposed
copper, No cords used as permanent
wiring, cover all breaker panels (Refer to NFPA 71E)
Tools and equipment – Look for damage, missing guards, missing
ground pins, know what items are double insulated vs. in need of a ground pin,
damaged cords, ground pins, exposed copper
GFCI – Ground Fault Circuit Interrupters – Electrical protection
Detects amperage drop and cuts power at 5mA bleed-off
Safety Training – Provided for employees for everything / on
a regular basis, must have documentation (training outline & sign in sheet
for employees)
Bottled gas storage – secured, caped, 25’ between oxy & acet.
or firewall separator, can be mounted on a torch cart
PPE (Personal Protective Equipment)– Safety glasses, face shields,
aprons, welding stuff – coat, gloves, head protection, proper clothing and
shoes
First aid – Must have available
Eye wash – Small portable bottles are available
Exposed insulation – Cover any combustible insulation with a
fire barrier
Housekeeping – clean work areas free of debris, floors and
benches, storage rooms
Dirty rag storage – Greasy and oily rags need to be stored in a
fire proof container with a lid
Record Keeping/Documentation – document all trainings, accidents
OSHA 200 & 201 log – Used thru 2002, 200 was internal
documentation, 201 was for posting – must post even if there were no injuries
OSHA 300 & 300A log – New for 2003, updated in 2004, watch dates
for posting the 300A
HAZ COM – Hazard communication training for employees
working with chemicals, clearly mark all bottles/containers, and get rid of all
2-4-d weed killers
General Storage – Eliminate anything that looks unsafe or
dangerous
Ladders – No damaged, modified, repaired, or painted
ladders, all ladders must have safety feet
Battery charging area – eye wash, fire ext (Proper rating), PPE, no
flammable/combustible material, proper battery acid storage (Refer to MSDS)
