It’s not everyday that the Occupational Safety and Health Administration (OSHA) comes knocking on the door of your facility. Often, employers aren’t thinking about how they are going to handle an audit until a Compliance Safety and Health Officer (CSHO) is standing on the front step. However, proactively developing a plan and training the correct staff could help prevent a citation. Our How to Handle a Safety Audit Toolbox Talk can help prepare your staff.
If a CSHO arrives at your business:
Notify the proper personnel and deny the CSHO entry until an appropriate management representative is available to escort them. The following individuals should be on site for an inspection: Environmental Health and Safety Manager, Maintenance Manager/Jobsite Superintendent, Plant Operations Manager/Jobsite Superintendent, and employee representatives.
Ask the right questions up front. When the CSHO arrives, they must first have an opening conference. During the conference, ask the reason for the visit, examples include complaint, random, industry-specific, and whistleblower. The CSHO will explain the inspection process, and you should ask questions such as:
- What areas of the facility/jobsite would they like to inspect?
- What documents/paperwork would they like to review?
- Can they provide a formal copy of any complaints?
- Is the visit related to safety or industrial hygiene?
Take them to the requested areas for inspection. Follow a direct route to reduce the overall scope of inspection. OSHA inspectors may cite violations that are “in plain view.” Do not volunteer to show the CSHO additional areas; only take them to areas they request to see.
Take photos/videos of everything the inspector does. Document, document, document! Inspectors are required to obtain inspection images and video recordings. Ensure you also protect yourself and your company by taking your own photos/videos of everything the inspector does, and file copies in your OSHA inspection folder.
If the CSHO finds a concern, work quickly and efficiently to get the problem or hazard mitigated. Ensure you have maintenance and labor personnel available to assist with fixing any issues.
If they request documents, only share the documents they ask for, and make extra copies to keep in an OSHA inspection file.
For industrial hygiene inspections, determine the type of monitoring the CSHO plans to conduct (e.g., noise monitoring, specific chemicals) and the number of individuals being monitored. Inspectors will usually permit employers to defer sampling for a period, allowing you to setup your own sampling equipment or to have a third party like RETTEW come in to match the sampling.
Closing Conference – All inspectors are required to have a closing conference immediately after an inspection. Industrial hygiene-related inspections will have a delayed conference because of the need to process and view analytical results. The closing conference is the best time to promote your company’s safety culture and commitment to excellence. The inspectors will review all alleged violations; take good notes, and if a remediation timeline is requested, ensure you give yourself ample time to correct violations. Respectfully dispute any issues or mistakes the CSHO noticed, but do not argue.
Recently, OSHA’s funding was significantly increased, and as a result, we can expect more CSHOs per region, raising your facility’s odds of an OSHA visit. RETTEW is available to help you prepare for an audit, walk you through an audit, or assist you with addressing any citations. Please contact Kelly Kramer, CECD, HEM, at 800.738.8395 for more information.
Safety training and consulting are only some of RETTEW’s 600+ services. Our safety team works hand in hand with engineers, scientists, project managers, and other technical experts at places such as manufacturing facilities, drill pads, and commercial construction sites. We are well respected in many industries and known for ensuring workers and equipment remain safe, which keeps your projects on track and your bottom line growing.