Presented By: Scott D. Cole, LEED GA, COSS, CSP
OSHA INSPECTIONS
ObjectivesWhen Can I Expect an OSHA Inspection?How Can I Prepare for an OSHA
Inspection?How Should I Handle an OSHA
Inspection?How Do I Close an OSHA Inspection?
2016 OSHA Citation Structure
Who is OSHA?
$592MM in 2016
7.3% Increase
37,785
Chemical Facilities
Why Would OSHA Inspect?CatastropheEmployee complaintProgrammed inspections
http://www.osha.gov/as/opa/foia/hot_11.html Invitation
Preparing Your OrganizationWritten programDrillsKnow your rights!
What Are My Employees’ Rights?Representation at opening and closing
conferenceRepresentation during the inspectionPrivate interviewsWhistleblowers protection
Managing the InspectionWarm welcome or demand a warrant?IdentificationWhat is the purpose of the inspection?Offer a beverage and a comfortable work
spaceKill them with kindness
The Opening ConferenceWho should be involved?Designate a scribeListenListenListenAnswer direct questionsDocumentation – know what’s required
The Physical InspectionAssemble your best teamPlan a route of travelTake photosFix it ASAPEmployee interviews
Physical ConditionsHousekeepingGuardingFall protectionIlluminationSanitationSignageSafety equipment
DocumentationOSHA logsExposure recordsWritten programs, SOPs, JHAs, etc.Training recordsMedical recordsDiscipline log
Written Programs – Not All-InclusiveHazard
CommunicationsRespiratory ProtectionHearing ConservationLockout / TagoutConfined SpaceBlood Borne
PathogensPPEExcavation Safety
Fire and Emergency Evacuation
Access to Employee Medical Records
Fall ProtectionElectrical SafetyLadder SafetyScaffold SafetyCrane Safety
The Closing ConferenceDesignate a scribeListenListenListenAsk but don’t argueDon’t make promisesThank you
The CitationReviewDocument corrective actions, if any and
postRequest an informal conference
Formal letterFile a Notice of Intent to Contest
15 business daysStep 1 – Administrative Law JudgeStep 2 – Full OSHRCStep 3 – US Circuit Court of Appeals
PenaltiesDependent upon how likely the violation is
to result in serious harm to employees Other-than-serious
$0 - $7,000Serious
$0 – 7,000Repeat and Willful
$0 - $70,000
August 1, 2016 PenaltiesDependent upon how likely the violation is
to result in serious harm to employees Other-than-serious
$0 - $12,000Serious
$0 – 12,000Repeat and Willful
$0 - $125,000
Questions?
THANK YOU
Scott D. Cole, LEED GA, COSS, CSPSteering Committee – Lake County Safety Council
V. President – Northern Ohio Chapter of the American Society of Safety Engineers
President – Cole Safety ServicesBusiness Unit Safety Director – Turner Construction Company
