Enforcement and Inspection

8 Steps to Take if OSHA Comes, and You’re Not There

OSHA can pull a surprise inspection at any time. If you’re not available to deal with them, what do you want your line supervisors and managers to do? Here are 8 suggested steps for them to take.

As a safety professional, you know there’s always the possibility that, on any day and at any time, you’ll have to deal with a surprise OSHA inspection.

If it happens, you’re ready. You know what you’re required to do and not do, to say and not say, to show and not show, and what your organization’s rights, protections, and responsibilities are under the law.

Let BLR teach supervisors and other frontline personnel how to deal with OSHA and their role in safety compliance at BLR’s special May 21 audio conference, titled Frontline Supervisors, Forepersons, and Managers: Why They Are Your First Line of Defense Against Injuries and Lawsuits; How to Optimize Their Role. Can’t attend? Preorder the CD. Satisfaction assured! Read more.

But what if that proverbial “knock at the door” (actually, appearance at the reception desk) comes when you’re away, perhaps visiting another facility, or at an offsite meeting or conference, or on those very rare occasions when you actually take vacation? Would the frontline supervisors or other personnel on duty, not schooled in dealing with inspections, know how to deal with one?

The possibility of that happening attracted us to a set of instructions for nonsafety professionals on dealing with OSHA inspections that we received recently. The list was prepared by Richard R. Bilheimer, CDS, a former senior safety specialist with Federal Express, and now president and owner of RRB Safety Consulting in Boca Raton, Florida.

Bilheimer laid out eight steps frontline managers or supervisors should take when OSHA comes to call. All presuppose that you’ll be in a location where you can’t get back in a reasonable time (“45 minutes or less is a good rule of thumb,” says Bilheimer). His suggestion is that you post this information where it’s readily accessible, if needed.

1. Ask to see the paperwork. That means asking for the official’s credentials and getting a business card. Then asking to see the complaint or other paperwork that generated the visit, and also requesting a copy.

2. If the officer asks for copies of your files or reports, and you’re a supervisor, explain that you are not authorized to give out or copy these documents without permission of a manager. If you are a manager, contact your legal or safety department before giving out any copies.

3. Take the officer only to the location listed on the agency’s paperwork, and do so by the most direct route. (Other experts have noted that an impromptu “grand tour” of your facility can easily turn into a fishing expedition for more citations.) Take a note pad or voice recorder and a camera, if available, to make your own record of what was said and what conditions existed at the location.

4. Answer only questions you are asked and only if you are absolutely certain of the answers. Do not volunteer information that is not asked for. This applies to managers and supervisors alike.

5. If an unsafe condition is found, do your very best to tell the officer that it will be corrected immediately. And if you are a manager, tell them that it will be corrected.

Supervisors, forepersons, and managers need to know OSHA compliance too. Help them learn at BLR’s special May 21 audio conference especially for them. Can’t attend? Preorder the CD. Satisfaction assured! Read more.

6. Following the visit, ask for a closing report and/or a conference to discuss any finding of deficiencies or violations. (You’re likely to get this anyway.)

7. Thank the official for his or her time spent and the knowledge you have gained from the visit.

8. Managers should immediately contact the legal department to inform them about the visit. Further action may be required to abate or challenge any findings or citations.

Bilheimer offers two more critical bits of advice: “Always be professional, courteous, and truthful,” he says. “And remember to always make these officials feel like they are our allies and not our adversaries.”

What advice on dealing with a surprise inspection would you give the frontline people at your organization? Use the Share Your Comments button below and let us know. To contact Richard Bilheimer, e-mail rbbsafetyconsulting@yahoo.com or call 561-487-3122.