By: Jeff Groce

Last quarter we detailed the different types of inspections that OSHA can perform. This quarter we will discuss the steps that a compliance officer takes upon coming onto your site and the Opening Conference.

A Compliance officer will come to the office trailer and introduce himself, show his credentials and then make the reason for his visit known. The compliance officer will tell you if it is a complaint, general schedule inspection, emphasis program inspection or if he is there for a fatality or catastrophe investigation.

As the compliance officer is going through the introduction and reason for being on site, he may or may not inform you of your constitutional rights, in that you have the right to request that he obtain a search warrant before being allowed to come on site. The compliance officer may not give advanced notice of the inspection before coming on site. He is not allowed to call a company and inform them that he will be showing up in site on such a date and at such a time. He is to just arrive on site, unannounced and find the superintendent.

Once he has introduced themselves and you have allowed them to be on site, they must hold an opening conference. The opening conference will be held with a representative from each contractor on site. The opening conference may be a held as a group and everyone attends. The compliance officer will tell everyone who they are and the reason for being on site.

The compliance officer will ask if each representative is an authorized representative of their respective companies. The authorized representative is just someone that can speak for the company at the opening, answer a few simple questions and is allowed to fill out a form that will contain the company information. The compliance officer will also request to see a copy of the company's Written Hazard Communication program and a copy of their MSDS manual. The questions that will be asked are how big is the company, total number of people and their union's local number, if they are a union signatory.

The compliance officer will then look over the written safety documentation that has been provided to them and then will look for the required postings, such as the OSHA poster and the OSHA 300 log if it is the time of year that it is required to be posted. After the program review and the posting, the compliance officer is ready to start the physical tour of the site and work areas. The inspection process will be covered in next quarter's newsletter.