Proactively Preparing for OSHA
I am assuming you are reading this because you have learned that you are in a high-risk occupation that is more likely to land you with a friendly visit from an OSHA compliance officer.
Later I’ll get into the details of what to expect during an on-site inspection, but first let’s review what preemptive measures you can take to ensure your workplace is in compliance with OSHA standards. While you may still be a target as a high-hazard industry, readying yourself for a visit will reduce on-the-job hazards, and decrease the chance inspections due to imminent danger, illness, injury, or employee complaints. The below tips can also help you avoid unexpected violations or citations, and generally prepare you to put your best foot forward should a visit occur.
Appoint a designated inspection team that can be quickly assembled in the event of an inspection. They should be familiar with all portions and protocol of an on-site OSHA inspection.
Make sure one person is responsible for meeting and greeting the inspector and reviewing their credentials. This person may also be responsible for retrieving and providing all documentation requested by an inspector during a visit.
Provide information and training to all workers about workplace hazards, methods to prevent them, and the OSHA standards that apply to the workplace. Note: this is an employee’s right, and should be available in multiple languages if you have employees who do not speak English as their primary language.
Organize periodic internal inspections using your own staff and appoint one person as the internal safety inspector. These both serve as good practice for an OSHA visit and can help address issues and remedy them prior to a formal OSHA on-site inspection.
Post all necessary safety decals and signs in the workplace. For example, you MUST prominently display the OSHA workplace poster (OSHA 3165) at all times. This poster explains employees' safety and health rights. The article “How to Pass an OSHA Inspection” includes an additional OSHA Health & Safety Label and Sign inspection checklist. Created by Graphic Products, the checklist addresses sign legibility, location, color and proper messaging.
In addition to personnelle, practice, and proper safety signs, your biggest advantage in a proactive approach is record keeping. I know, it’s a pain in the ass, but I cannot stress the importance of keeping thorough and up-to-date documentation. If this is not your strong suit, determine which employee possesses the organizational skills that you lack and make them your responsible record keeper. A few quick facts on OSHA documentation and workplace requirements:
Employers must report all work-related fatalities within 8 hours!
Employers must report all work-related inpatient hospitalizations, amputations, or losses of an eye within 24 hours.
Employers with more than 10 employees are required to complete both OSHA Form 300 Log of Work-Related Injuries and Illnesses and OSHA Form 300-A Summary of Work-Related Injuries and Illnesses and post them in the workplace.
Minor injuries requiring first aid only do not need to be recorded.
Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year.
The records must be maintained at the worksite for at least five years.
If requested, copies of the records must be provided to current and former employees, or their representatives.
Additionally, you should always be prepared with the following OSHA required record keeping:
A written hazard communication program
Emergency preparedness and evacuation procedures
Written lockout/tag out (LO/TO) programs
Exposure and medical records
Material safety data sheets (MSDS)
Bloodborne pathogen training documentation
Alright, that’s all I’ve got! You’re now better equipped with the tools to build a safer work environment that meets OSHA’s standards. Still scared? Next, I’ll be walking you through everything you need to know about an actual on-site OSHA inspection from start to finish.