Successfully Handling an OSHA Inspection

By Diane M. Calabrese / Published July 2022

The goal: Each person who goes to a workplace in the morning returns home intact in the evening. 

     Regulations from the Occupational Safety and Health Administration (OSHA) are designed to reduce workplace hazards and to prevent injuries, illnesses, and deaths in the workplace. To ensure rules are followed, OSHA conducts inspections.

     The way OSHA prioritizes inspections means some workplaces may receive more visits than others. Situations determined to present an imminent danger, or a spate of reported illnesses or injuries, will bring inspectors. So, too, will worker complaints and referrals (from other regulatory agencies). 

     Some OSHA inspections fall into the targeted category. That is, an industry that’s having many health or safety issues becomes the focus of stricter enforcement. Many inspections are of the follow-up sort to ensure issues cited by inspectors have been corrected.

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     Scrupulously following regulations is synonymous with being prepared to successfully handle an OSHA inspection. But are the mandated and regular safety training and meetings at a workplace sufficient preparation?

     “For an inspection, yes, but I believe that is not enough,” says Michael Hinderliter, president at Steamaway Inc. in Fort Worth, TX. “OSHA wants to see there is a ‘real’ culture for safety.”

     To assess the culture during an inspection, OSHA might look to see how the employer warns and writes up employees who deviate from absolute adherence to safety guidelines. Training, in a sense, is just one side of the two-sided coin. Reinforcement is the other.

     “It is easy to do the training,” says Hinderliter. “Enforcing the training and practices are far more important to create a culture of safety.”

     Does Hinderliter recommend using an outside consultant to evaluate and verify that a company is ready for an OSHA inspection? “I do,” he says. “Business owners generally have some knowledge but are not experts on the safety and the updating of regulations.”

     Indeed, Hinderliter says there is real value in turning to someone outside the company for assistance. “Find a good consultant to come in and evaluate the operations. They can identify hazards and create practices to reduce accidents.”

     Training, of course, is inextricably tied to establishing a safe workplace environment. “There are several responsibilities that company owners have toward their employees and providing a safe workplace,” says Michael Draper, a trainer with Expert Safety Services in Belleview, OH, and the safety director for PWNA. “Training is certainly one of them, but there are other things as well.”

     Like Hinderliter, Draper believes that bringing in an outside consultant can be useful, “most specifically to get the company on the right track and to put a system of safety in place,” he says.

     With so many regulations and frequent updates and changes, should a company have a person with responsibility for keeping pace with rules? “This is really going to depend on the size of the company,” says Draper. “Most small companies won’t be able to afford this. However, there are programs available to smaller contractors that will help them get going.”

     One program that is available, OSHA consultation, gets attention in the last section. In addition, help comes from OSHA via fact sheets, tutorials, and interactive modules.

     The OSHA Fact Sheet on inspections (https://www.osha.gov/sites/default/files/publications/factsheet-inspections.pdf) and the OSHA Hazard Identification Training Tool (https://www.osha.gov/hazfinder/how-to-play) offer a good foundation. The latter allows employees to identify hazards in a simulated online “game” that may be an ideal way to engage some members of the team. (Safety training tools must all focus on the same end, but the path can be different.)

How To Build That Culture

     “Safety is reflected in the culture of an organization,” says Mike Gruver, general manager at Hydrus Detergents in Estherville, IA. “As a distributor, give your employees a duffle bag with all the PPE they’ll need—gloves, face shield, apron, googles, ear plugs…”

     But start at the absolute source. “Safety should be planned into your equipment designs,” says Gruver. “Ask yourself the hard questions about what could go wrong. “

     Moreover, ensure that tough self-assessment includes everyone engaged with a business. That means looking beyond the employees to the customers.

     “Educate your customer about how a single safety incident can cost, on average, more than $20,000,” says Gruver. “While their response may be ‘That’s what insurance is for,’ what would you think if it happened to you?”

     Gruver’s point about insured losses merits reemphasis. Novices to business—and to purchasers of insurance—fail to factor in the cost of an incident (the cost beyond injury or damage). Incidents result in higher premiums, not just for the claimant but also for the pool to which the claimant belongs. Safety saves lives and money. 

     Over the years, this writer has heard the same sentiment expressed by a long-haul trucker and an emergency room physician. Slow down. Save lives.

     To be sure, Gruver expresses the same sentiment. “Slower is sometimes faster to perform a task safely without risk of injury,” he explains.

     Fitting the tool to the task may seem an obvious component of safety. But from contractors using the wrong ladder “just once” to a brick-and-mortar company not salting the walk because the temperature will warm up “soon enough,” lapses occur. Avoid the lapses by using as a template Gruver’s recommendations for chemicals.

     “Chemical safety relies on a highly effective initial chemical assessment to solve a customer problem,” says Gruver. It encompasses substrates, soils, expectations, tools the customer has, and the environment. 

     Safety is enculturated “by looking at the whole on each and every occasion,” explains Gruver. “Situations may be similar,” but it’s imperative to “respect the differences and plan accordingly.”

     Gruver sums it up this way: “Safety has to be part of the implementation plan, not an afterthought.”

Be Prepared

     Routine training and evaluation of employees coupled with a culture of safety fortified each day are the basics of being ready (at any time) for an OSHA inspection. Derek E. Presley, the safety manager at Chappell Supply and Equipment in Oklahoma City, OK, includes an epigram in his signature that sums it up: “The price of safety is always paid in advance.”

     Presley has more than 20 years of experience working as a safety manager. And he offers some specific guidance for success in consistently meeting OSHA’s expectations.

     “OSHA inspections are not only about crossing the t’s and dotting the i’s, but also about ensuring that the end users are knowledgeable about the needed subjects to ensure effectiveness of a particular subject and that up-to-date programs and policies are in place and being utilized,” says Presley.

     “During an inspection, your employees will be asked to operate a particular machine or asked about a particular subject, and they should be able to talk knowledgeably about it,” explains Presley. Although inspectors may pursue certain subjects, they can branch out to any part of the operation. 

     Work with OSHA by seeking free guidance. “I have always invited OSHA into my facility after the first six months of my new employment,” says Presley. The visit ensures that everyone—regulator and regulated—are seeing things the same way and at the same baseline.

     “OSHA is made up of two divisions, a consultation division and a citations division,” explains Presley. A company can request a visit from the consultation division.

     In turn, the consultation division provides an action items report, says Presley. A company is then given time to mitigate any items needing attention. 

     Not only is the consultation free of charge, says Presley, but during the mitigation interval, the company cannot be visited for an inspection. “This program is always looked upon favorably in all OSHA realms.”

     Abundant help is available from OSHA. For example, companies can subscribe to alerts about rules and rule changes. 

     “I think it should be a team effort to stay informed about changes,” says Presley. The safety professional at the company should note changes and then “inform the leadership and develop a plan to implement the needed changes and conduct training if applicable.”

     The leadership involvement is essential. “A true safety management system is only as effective as the leadership allows it to be,” says Presley. “[And] every employee must be involved—a knowledgeable employee is always a better employee.”

     Strong leadership on safety requires follow-up regarding errant practices, conditions, and habits in the workplace, explains Presley. It also demands an interest in identifying root causes. Root-cause analysis is “vital to mitigation” because it teases out the components that over time led up to an event—to eliminate them in future. 

     Management must be involved; safety budgets should exist, and safety statistics should be retained and reviewed by leadership. Those are other recommendations from Presley.

     “Leadership should engage with the workforce daily—a small pat on the back goes a long way,” says Presley. “The adage is, ‘If it’s important to my boss, it is important to me.’ Show safety is important through action, not words.”

     The result, says Presley, is safety and readiness. “Engaged leadership builds and/or strengthens your safety culture and is the best way to guarantee a more productive workforce and a successful OSHA inspection.”