What to Do Before OSHA Comes Knocking

Every year, the U.S. Occupational Safety and Health Administration (OSHA) inspects workplaces around the country for safety and occupational hazards. In 2017 alone, OSHA conducted 32,408 inspections – more than half of which were unprogrammed inspections.
There are six reasons OSHA might come knocking on the door. They are (in order of priority): 
  1. imminent danger situations;
  2. severe injuries and illnesses;
  3. worker complaints;
  4. referrals;
  5. targeted inspections; and
  6. follow-up inspections.
OSHA determines which workplaces are the most hazardous by using the Days Away, Restricted or Transferred (DART) rate, a measurement of workplace injuries and illnesses that result in time away from work, restricted job roles or permanent transfers to new positions. Companies with a rate of seven or higher are immediately listed on OSHA’s inspection list.
To calculate the company’s DART rate using this formula: (N/EH) x 200,000, where “N” is the number of cases involving days away from work, restricted work activity or job transfers due to an incident and “EH” is the total number of hours worked by all employees in the calendar year.
During an inspection, OSHA’s compliance safety and health officers scrutinize nearly every component of a company’s health and safety programs, including the working conditions, written policies and procedures, employee trainings, record keeping requirements, documentation of routine safety inspections and more. When companies are not well prepared, an investigation can result in hefty fines and penalties.
To keep the company off OSHA’s list, here are four tips to help prepare for an OSHA inspection:
  1. Educate the team. It’s not uncommon for OSHA compliance safety and health officers to hold interviews with employees during an inspection, so it’s important that every employee understands what the process might look like. Some insurance companies provide free consultations on OSHA preparedness and can send a representative to train managers and team members who might be involved in the inspection. Be sure to discuss this possibility with the company’s broker.
  2. Assign an inspection oversight committee. Gather a group of employees who will be responsible for escorting the inspector around the worksite. These team members should be fully vetted on the company’s safety procedures. For example, it’s important that they make sure records are easily accessible during an inspection, coordinate interviews with employees if the inspector asks, take notes and photographs during the inspection to note any citations that will need to be corrected, among other things. 
  3. Get paperwork in order. OSHA inspectors will request company records of all work-related injuries and illnesses. Make sure OSHA 300 logs are organized and updated regularly – well before an inspection is even suspected. Train employees on how to log incidents with accurate and detailed information in case inspectors have any questions about an incident. 
  4. Practice proactivity. The best way to be prepared for an OSHA inspection is to conduct a run through or test every so often to identify potential health and safety issues that an OSHA inspector might find. This way company personnel can catch issues before an inspector does and correct them immediately. Being cognizant of how the company is keeping up with health and safety protocols, and fixing those snags along the way, may eradicate any problems that would warrant an inspection in the first place.
While a surprise OSHA inspection – or even a planned one – can be nerve-wracking, don’t treat it like a fire drill. Eliminate some of the stress by following the tips mentioned above so the company is ready if and when OSHA comes knocking.