In the first two installments we looked at the different types of inspections that OSHA can conduct and the Opening Conference of an OSHA inspection. In this installment, we will take a brief look at the actual inspection process. While this is the hands on site walk, there are some things to be aware of.
Company Representative. Have a company representative from the site available or designated, to walk the site with the compliance officer. This company representative should have the authority to correct issues and direct employees, so that things can be corrected while the compliance officer is on site.
Have a camera on site. The compliance officer will have one. Have the designated company representative take the camera on the walk-through and take a picture of everything the compliance officer takes a picture of. The company representative should feel free to ask the compliance officer to wait while he takes a picture as well.
Note pad. The company representative should have a note pad and pencil so that they can write down the issues that the compliance officer notes. The compliance officer will take note, especially concerning the specifics about a violation. Do not be afraid to ask the compliance officer what the violation is, if it is not obvious. Example: if it is a violation involving a power tool, the compliance officer will note the make, model, serial number, model number, color and what is wrong with the tool.
During the site inspection, the compliance officer will walk the jobsite to inspect the site from top to bottom. The compliance officer will take photographs of issues and violations and the company representative should take the same picture. The company rep should then, do everything possible to have the violation corrected right then. It will show the compliance officer that the company is serious when it comes to safety, and it will enable the compliance officer to see that the violation was corrected and he can write on the citation that it was corrected on site.
While on the walkthrough, the compliance officer will ask to interview employees. The company representative can help facilitate this process. Although the company representative may not be present during the interview process, the company representative can help calm the employees if they have problems in talking with the compliance officers. Sometimes employees think they are in trouble or will be in trouble if the talk to the compliance officers. The company representative, if needed, can tell the employees that it is ok to talk to the compliance officer and answer his questions.
When the compliance officer finds a violation, the company representative may be trying to figure out how to correct the issue, feel free to ask the compliance officer. While the compliance officer cannot tell you how to correct an issue, he may say things like: “in the past”, “I have seen it done this way”. The compliance officer is not allowed to tell a company how to fix an issue, but they can tell you what they have seen in the past on other jobs and with other companies that might be able to applied to this site.
The compliance officer will inspect the entire site and gang boxes. Employee’s tools being used on site will be inspected as well and if there are violations with those tools, those violations go against the company. Tools locked in personal vehicles should not be inspected.
If the site is a multi-employer site, the compliance officer will inspect one company completely then start with another company, then move to a third, as so on until each contractor has been inspected. The only way that all companies will not be inspected is if the inspection resulted from a complaint or an emphasis program. Those may be expanded, if the compliance officer sees a serious violation while conducting the inspection for the reason they are on site.
After the compliance officer finishes his inspection, he will get ready for the closing conference. Next newsletter we will go in-depth with the closing conference.