OSHA Safety Inspection – What to Expect

Forklift safety in the United States is regulated by the OSHA (Occupational Safety and Health Administration). While the OSHA’s forklift regulations are focused around forklift safety and forklift training their oversight is not limited to forklift operation. The OSHA also oversees all workplace health and safety regulations. When they perform an inspection it’s rarely limited to forklift operation safety and health. For this reason it’s important to understand what happens during an inspection and to consider how it can apply to forklift operation, training, and safety, but to also consider how can impact your business, your co-workers, and yourself.

OSHA Workplace Inspections

Inspections are not very common. The OSHA cannot inspect every workplace nor does it really want to. They focus their resources on the most hazardous workplaces and use the following priorities to guide their actions:

  • Imminent danger situations – hazards that could cause physical harm or death
  • Fatalities and catastrophes – incidents that involve death or hospitalization of 3 or more individuals
  • Complaints – violation allegations – employees can request to remain anonymous
  • Referrals – violation reports from other agencies, organizations, or individuals
  • Follow-ups – from previous inspections
  • Planned investigations – aimed at high hazard, high risk industries

What to expect

Inspections are usually conducted without advanced notice, however there are circumstances where an inspector will give prior notice. These are typically cases where individuals are in imminent danger and corrective action needs to be taken immediately or when the investigation needs to be performed during off hours. If notice is given, there is an obligation to inform employees of the upcoming inspection.

Before an inspector begins an on site assessment, they will research inspection history and review standards that are most likely to apply to the situation. They will also familiarize themselves with the nature of the business and consider potential hazards.

Inspector credentials

When the inspector (compliance officer) first arrives onsite, they will present their credentials (photograph and serial number). Employers have the right to call the nearest OSHA office and verify their credentials before proceeding.

The opening conference

The compliance officer will explain the purpose of the visit, how the location was selected, and the scope of the inspection. If a complaint was filed by an employee, their name will not appear on any documentation.

The compliance officer will ask the employer to select a representative to accompany them during the inspection. They will also ask an employee representative to join the opening conference. Employees can select an individual to represent them or if a bargaining agreement or safety committee exists, a representative will be selected based on their guidelines.

The walkthrough

The compliance officer, employer and employee representatives will walk through the workplace to inspect the area for safety and health hazards. The route will be selected by the officer who will attempt to minimize work interruptions. If necessary the officer will take photos, videos, instrument readings, examine records, collect air samples, measure noise levels, as well as observer employee contact with hazardous materials and toxins.

An inspection may be expanded to a larger area at the discretion of the officer. If they discover a violation in open view, the officer is more likely to ask to continue the inspection.

The OSHA places a lot of importance on record keeping and the posting of required records. The compliance officer will review records of on the job injury, illness, and death. They will ensure that a copy of totals from the last page of OSHA Form Number 300 are posted in a public place along with poster OSHA 3165 which details employee health and safety information.

The OSHA compliance officer will want to see a copy of the employer’s Hazard Communication Program – employers must have a written communication program that includes information on safety data sheets, labeling of containers, and an employee training program. The Hazard Communication Program should maintain a list of hazardous chemicals in the workplace along with how the employer communicates the hazards associated with each chemical.

During the walkthrough, the officer may point out unsafe conditions to the employer and will convey necessary corrective action. If a correction can be made on the spot, it is to the advantage of the employer to make the adjustment right away – it shows a desire for high safety standards and corrections can be a factor in the officer’s final findings.

The closing conference

At the end of the inspection the OSHA officer will meet with the employer and the employee representative to discuss any unsafe and unhealthy conditions observed. They will also identify all violations for which they may recommend a citation.

More information
http://www.osha.gov/Publications/osha2098.pdf