If OSHA (State or Federal) Shows up:
SAFETY COACHING UPDATE SUBMITTED BY BEN W. LAVERTY, III, PhD, CSP, FACFE. RCEPA
You may request the inspector delay inspection for up to 60 minutes to wait for appropriate personnel to be available (e.g. manager/supervisor/safety coordinator/consultant).
- Opening Conference: Issues to be reviewed.
- Have IIPP available;
- Have training records available;
- Have disciplinary notice(s) available;
- Have 5 years of OSHA 300 Logs with current year included
- Have 5 years of OSHA 300A Logs with current year included
- Escort OSHA person to accident scene using route least likely to offer the OSHA person a view of other operations.
- Be truthful and brief when answering questions.
- Do not pass any judgements on: injured individuals, (verbal or mutual), training programs, competency or supervisory personnel at time of inspection (get all available evidence first).
- Make copies of or note any statements made by OSHA inspector.
- If inspector takes a picture, a mirror image of that picture MUST BE taken by company personnel, downloaded, notated and put into the investigation file.
- Never argue with a OSHA representative.
- Do not ask if there will be a citation.
- Do not say that you think a citation should be written even if at the time you may think one is deserved. (Yet to be discovered evidence could change your mind…you will have difficulty in taking the statement back).
- Be on the alert for verbal entrapment. The inspector will often:
- Ask, ask, ask – is the answer the same each time?
- Implying “another” usually higher-ranking individual, said the facts were different.
- Let Cal/OSHA expert draw and report on any preliminary conclusion, not you.
- Don’t get hooked with “what do you think.” Answer with, “I’m holding off on making conclusions until I have all the information.”
- Closing Conference: Listen and take notes.
We hope this information helps you when you have an OSHA inspector.