OSHA Inspection: How to Prepare and Pass It [+Checklist]

August 19, 2019 in Regulatory Compliance Checklists



OSHA Inspection: How to Prepare and Pass It [+Checklist]

To prepare for an OSHA Inspection, you need to know what to expect. The best organizations prepare for the unexpected.

Are you scratching your head wondering how you can prepare for a surprise visit?

The simplest approach: create an operational culture that encompasses OSHA policies.

The idea is similar to the concept of having a 3-Day emergency preparedness kit in your home. Granted, there’s a low probability of a disaster ever occurring that requires your kit. However, you’ll be glad you made an effort if it makes the difference between life and death in that unfortunate circumstance.

Unlike low probability natural disasters, OSHA related accidents happen daily across the country with an average of 14 workplace fatalities occurring every day.

Like-minded business owners also see the wisdom of being prepared for OSHA visits, even if they don’t end up happening.

Should You Be Concerned About Getting an OSHA Inspection?

It depends. Yes. And maybe.

Let me explain that a little further.
First, it’s going to depend on whether you have a business that is covered by
the OSH Act.

For the most part, OSHA applies to any business with more than ten employees. Those businesses are required to meet OSHA standards and maintain appropriate records.

When it comes to exemptions from OSHA, there are some general exclusions tacked onto the less than ten employees disqualification.

Generally speaking, OSHA exclusions and exemptions include churches, federal and state-level government organizations, and their political subdivisions. Businesses that are regulated by federal statutes (ex. mining and nuclear power companies) tend to also be exempt.

If you have less than ten employees and meet the above exemptions, then you might not need to worry about getting an inspection.

Why the uncertainty? OSHA doesn’t have a limitless roster of inspectors. And the inspectors that they do have already manage about 100,000 inspections a year.

There are roughly 8-10 million OSHA regulated businesses in the US, so there is a ~1% chance your business is selected for one of the 100,000 inspections.

That said, just as you would immediately regret not having an emergency preparedness kit if a disaster strikes, it pays to be prepared. Plus, OSHA regulations are in place for a reason – keeping your employees safe should be a priority even without the threat of legal liabilities.

Key takeaways:

  1. OSHA regulations apply to any business that has more than ten employees and requires them to meet its standards and maintain appropriate records.
  2. Exemptions exist for certain businesses, but that doesn’t mean you can or should run a lawless operation. If care about the well being of your employees, then most OSHA rules should be enforced anyway.
  3. There are roughly 100,000 inspections done annually in the United States, yet 14 US workers are involved in preventable workplace deaths EACH DAY.

Preparing
for the OSHA Inspection Process

If your business falls under the purview of OSHA regulations, you need to have a system in place and maintain accessible records. In the event of an inspection, you’ll thank yourself for making the effort.

I am going to detail six ways you can be ready
and prepared if an inspection comes knocking on your door.

FYI, you are allowed to and should verify any inspector’s credentials. Do not share any information until you have done this.

   › Establish Key
Points of Contact  

It’s imperative that you have chosen and designated key points of contact before an inspection. This person should be intimately familiar with your business’s inspection protocols and record keeping. Without this person, you’ve already significantly lowered your chances of passing inspection.

This person should be extremely professional, calm under pressure and able to maintain composure should the inspector ask tough questions.

Your key contact needs to be familiar with the OSHA inspection process, particularly with the rules that apply to your industry and processes.

It’s also the responsibility of your contact person to make sure your team is aware of their rights when being interviewed.

It’s a good idea to have a backup or assistant contact in place who is also familiar with your records and the general inspection process in the event an inspector arrives when your key contact isn’t there or available.

Key takeaways:

  1. Not having a contact person lowers your chances of passing inspection.
  2. Your contact person needs to be familiar with the OSHA inspection process and your record keeping.
  3. Your key contact should make sure your team is aware of their rights when being interviewed by an OSHA Inspector.

   › Have a Response
Team in Place

Readiness should include having a response team
in place.

This response team can be made up of two or three people who want to be involved and responsible for understanding inspection processes.

This team needs to have a solid understanding of your company’s compliance practices and standards so they can help enforce them throughout your company.

This team will likely include your ‘backup’ key contacts so that they can be ready to jump into action should an inspector come knocking.

   › Maintain Your
Professionalism at all Times

Professional behavior should be common sense, but unfortunately, inspectors are frequently treated with hostility and disrespect.

Being rude or argumentive lowers the chance of you passing your inspection. Make sure your contact and response personnel—and frankly, everyone else too—can maintain a professional demeanor at all times.

If, during the course of the inspection, you enter areas where protective gear is necessary, politely ask the inspector to suit-up. This is a good way to show that your company pays attention and to and maintains compliance to safety standards at all times.

Key takeaways:

  1. Always be professional and polite – inspectors are human too!
  2. Enforce protective gear policy with inspectors, they may be testing if you if they don’t initiate it.

   › Have the Right Information
Available

Members of your contact and response teams must be able to provide the needed information and answer any questions.

Important information could include:

  • General information about your business – including the number of employees, products/services produced, materials used, etc.
  • The names and contact information for management personnel – managers, supervisors, etc
  • Employee injury and illness logs
  • Inspection processes and procedure records

The above criteria are the bare minimum that you should expect to procure for an inspection. Being able to quickly retrieve your inspection history with an audit trail of dates will go a long way towards leaving a positive impression and passing the inspection.

   › Have a
Predetermined Walk-Around Route

There’s a good chance the inspector may want to inspect a certain part of your plant and/or specific machines and equipment. Your key contact needs to have a planned walkthrough route ready and know what they will be showing.

However, the inspector is within their rights to pick and choose what to look at and where to go. If they do have specific objectives in mind, it’s important to be equipped to answer any questions they may have or have a nearby resource who can go into any pertinent details.

   › Have Your
Records Available

If you are using software like MaintainX, your organization’s records will be available at your fingertips and easily exportable. With MaintainX, you can create digital versions of your inspections and checklists that can be completed by your team.

Be sure to have your records on leading indicators, workers’ compensation, safety, insurance, and general liability easily accessible and available. It helps to show your readiness and compliance.

Six Steps to OSHA Inspection Readiness 
1Establish Key Points of Contact
2Have a Response Team in Place
3Maintain Your Professionalism at all Times
4Have the Right Information Available
5Have a Predetermined Walk-Around Route
6Have Your Records Available

OSHA Inspection Checklists

There a vast number of OSHA inspection checklists and regulations covering a variety of issues. To give an example of what they look like, we have shared one below.

We’ll just cover one here, but I should note that MaintainX, mentioned above, is a great way to create your own custom checklists using the exact OSHA rules and regulations.

   › OSHA Forklift Inspection
Requirements

Safety and Operational Checks for Gas/LPG/Diesel
Trucks & Forklifts (Prior to Each Shift)  

See here
for electric vehicles.

Engine Off Checks

  • Leaks – Fuel, Hydraulic Oil, Engine Oil or Radiator Coolant
  • Tires – Condition and Pressure
  • Forks, Top Clip Retaining Pin and Heel – Check Condition
  • Load Backrest – Securely Attached
  • Hydraulic Hoses, Mast Chains, Cables and Stops – Check Visually
  • Overhead Guard – Attached
  • Finger Guards – Attached
  • Propane Tank (LP Gas Truck) – Rust Corrosion, Damage
  • Safety Warnings – Attached (Refer to Parts Manual for Location)
  • Battery – Check Water/Electrolyte Level and Charge
  • All Engine Belts – Check Visually
  • Hydraulic Fluid Level – Check Level
  • Engine Oil Level – Dipstick
  • Transmission Fluid Level – Dipstick
  • Engine Air Cleaner – Squeeze Rubber Dirt Trap or Check the Restriction Alarm (if equipped)
  • Fuel Sedimentor (Diesel)
  • Radiator Coolant – Check Level
  • Operator’s Manual – In Container
  • Nameplate – Attached and Information Matches Model, Serial Number, and Attachments
  • Seat Belt – Functioning Smoothly
  • Hood Latch – Adjusted and Securely Fastened
  • Brake Fluid – Check Level

Engine On Checks – Unusual Noises Must Be Investigated
Immediately

  • Accelerator or Direction Control Pedal – Functioning Smoothly
  • Service Brake – Functioning Smoothly
  • Parking Brake – Functioning Smoothly
  • Steering Operation – Functioning Smoothly
  • Drive Control – Forward/Reverse – Functioning Smoothly
  • Tilt Control – Forward and Back – Functioning Smoothly
  • Hoist and Lowering Control – Functioning Smoothly
  • Attachment Control – Operation
  • Horn and Lights – Functioning
  • Cab (if equipped) – Heater, Defroster, Wipers – Functioning
  • Gauges: Ammeter, Engine Oil Pressure, Hour Meter, Fuel Level,
    Temperature, Instrument Monitors – Functioning

OSHA also provides brochures and fact sheets on nearly every type of equipment. For example, if you need info on an OSHA crane inspection, let Google be your friend. A quick Google search will bring up pages like this with fact sheets, flow charts, safety tip sheets, cards, and more.

Be Prepared to Put the Safety of Your Employees First

While the focus of this article has centered around preparing your business to comply with federal regulations and inspections, it is important to remember why this exists. OSHA was put in place to stem the increasing rates of workplace injuries and fatalities that surged in the 1960s. Since its inception, the U.S. occupational injury rate is 40 percent lower and deaths from occupational injuries are at an all-time low — 60 percent lower than 30 years ago. 

Regardless of your feelings on government oversight, these well-intentioned rules can help keep your employees safe and productive to enable long-term business success.

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