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Toolbox Talk: Be Ready for a Compliance Inspection

By May 28, 2020 No Comments

Being Prepared for Compliance Inspections

No matter how many Federal and State workplace safety inspections you’ve been through, the sound of an inspector knocking may still make you anxious. In most cases, OSHA (WISHA) inspectors—also known as Compliance Safety and Health Officers (CSHOs)—will arrive at your workplace without providing advanced notice. As a result, safety inspections often come as a surprise to the employer, which only adds to the uncertainty and anxiety.

That said, by knowing the protocol inspectors follow and how the agency decides which facilities to inspect and which to pass over, safety professionals can be confident that even if they don’t know when OSHA is coming, they are fully prepared to welcome and impress the inspector.

What to Do When a Compliance Officer Arrives On Site

This information is important for all Garco employees and managers to know ahead of time. Be sure everyone working on your site is familiar with this information.

  1. Notify the person responsible for the site, such as the Safety Department, project manager, project superintendent and owner.
  2. Request identification, write down the Compliance Officer’s name and ID number, and ask which area office they represent.
  3. The purpose of the inspection should be stated by the Compliance Officer before or during an opening conference at the beginning of the visit.
  4. Inform the Compliance Officer that Garco is a member of the AGC Safety Team; this will help ensure that the inspection stays a focused inspection and not a board scope inspection.
  5. A member of the site management team shall always escort the Compliance Officer.
  6. During the walk-around inspection, the Compliance Officer is permitted to take notes and photographs and shall comply with the safety and health rules required at the job site.
  7. Employees may be interviewed or written statements may be requested.
  8. A company representative should take notes and photos of all inspection activities.
  9. A closing conference will be arranged to allow the Compliance Officer to review any violations observed and refer to applicable OSHA standards.
  10. Instructions on follow-up procedures will be provided at the end of the inspection.

During the inspection, everyone on site should:

  • Be cooperative
  • Do not evade questions or try to hide anything
  • Answer questions truthfully without speculation
  • Do not be sarcastic or argumentative
  • Take the same notes, measurements and photos as the compliance officer.
  • If possible, fix any violation immediately

Commonly Asked Questions

  1. Can the foreman of the job site refuse to let the Compliance Officer on site? Yes, but it is not recommended. It is always best to cooperate with any federal or state compliance officer.
  1. Does the Compliance Officer need to show a warrant? No, but entry can be refused until a warrant is provided. However, cooperation with OSHA/WISHA is always recommended and granting immediate entry will get the inspection off to a good start.
  1. Can an employee refuse to be interviewed? Yes, but cooperation by all employees is advisable. An employee can ask that they have another person (safety officer, foremen, union representative, etc.) with them during the interview.
  1. If hardhats or PPE are required in the work area, can the Compliance Officer refuse to comply with the PPE requirements since they work for OSHA/WISHA? No, the Compliance Officer must wear all PPE that is required in the work area(s) they are inspecting.

Remember, success starts with safety!