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Would you be ready for an Occupational Health and Safety Administration (OSHA) inspection?  Do you believe your company is in compliance with OSHA regulations?  Are your policies protecting your employees from unintended workplace hazards based on regulatory compliance and best management practices (BMP)

A company’s compliance status with OSHA regulations and industry best management practices is of vital importance to all businesses employing a workforce.  OSHA citations are disruptive, and fines can be financially impacting reach thousands of dollars.  Insurance premiums can skyrocket for major or frequent injury or illness claims.

Personal injury or death lawsuit can be very costly, not just financially, but also to a company’s reputation and the ability to retain and attract employees. All of these are substantial reasons for business owners to understand where theirs fit from a compliance standpoint with OSHA regulations and best management practices related to a healthy and safe workplace.

What are OSHA Compliance Audits? 

Did you know under the OSH Act, employers have a duty to provide a safe workplace? Key responsibilities of an employer include the following:

  • Provide a workplace free from recognized hazards and comply with standards, rules and regulations issued under the OSH Act.
  • Regularly assess workplace conditions to verify conformity to applicable OSHA standards.
  • Ensure employees have and use safe work practices, tools and equipment and properly maintain this equipment.
  • Use color codes, posters, labels and signage to inform and warn employees of potential hazards.
  • Correct cited violations by the deadline set in the OSHA citation and submit required abatement verification documentation.
  • Establish and/or update existing operating procedures and communication to employees to affirm comprehension and observance of safety and health requirements.  This includes written programs specifically required under the OSH Act.
  • Employers must provide safety training in a language and vocabulary workers can comprehend.
  • Employers using hazardous chemicals in their workplaces must develop and implement a written hazard communication program (HAZCOMM) and inform and train employees about the hazards, exposure risks and proper precautions (and a copy of safety data sheets must be readily accessible). 
  • Post, at a prominent location within the workplace, all applicable OSHA posters (or the state-plan equivalent posters informing employees of their rights and responsibilities.
  • Provide medical examinations and training where required under OSHA standards.
  • Report all work-related fatalities to OSHA within 8 hours of incident, and all work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours. 
  • Keep records of work-related injuries and illnesses. Employers with 10 or fewer employees and employers in certain low-hazard industries are exempt from this requirement.
  • Provide accessibility to the Log of Work-Related Injuries and Illnesses (OSHA Form 300) records. On February 1, and for three months, covered employers (see above) must post the summary of their OSHA Form 300A log of injuries and illnesses and make it accessible to all employees, former employees, and their representatives.
  • Provide access to employee medical records and exposure records to employees or their authorized representatives.
  • Provide to the OSHA compliance officer the names of authorized employee/company representatives who may be asked to accompany the compliance officer during an inspection.
  • Not discriminate or retaliate against employees who exercise their rights under the Act (Whistleblower Protection).
  • Post OSHA citations at or near the work area involved until the violation has been corrected, or for three working days, whichever is longer. Post abatement verification documents or tags.

Required OSHA Health & Safety Programs

Within this list of employer responsibilities, there are specific, and sometimes complicated, health & safety programs required, such as Pandemic Response (COVID-19), Hazard Communications (including handling of hazardous chemicals and hazardous waste), Control of Hazardous Energy (LOTO), Confined Spaces, and Respiratory Protection, just to name a few. 

Along with these required programs comes important OSHA required employee training and written programs, record keeping, and the identification of hazards and employee exposures.

OSHA generally does not perform pop up inspections without a specific reason. What can prompt an OSHA inspection includes employee complaints, major or frequent injuries or amputation that require hospitalization and are reported to OSHA by requirement, or an employee death. These events will most certainly lead to an inspection and often fines. OSHA implements a National Emphasis Program (NEP) annually that involves selecting a high-risk hazard, such as COVID-19 or silica exposures, and directing resources to inspect businesses in industries with the greatest potential for employee exposures to these hazards. This would most likely be where you may receive a pop up, unannounced OSHA inspection. Readiness for an OSHA inspection, and understanding how to respond to an OSHA inspection, complaint, or fine is very important for businesses to get back to normal business activities, alleviate scrutiny, and assure employees and customers that your business takes workplace health and safety serious and you are taking adequate and appropriate actions when needed.

RHP’s Certified Industrial Hygienists and Certified Safety Professionals can help you be prepared for an OSHA inspection by performing OSHA and Health & Safety compliance audits for your business. An audit generally consists of a facility walk-through to better understand your business’s processes, understand and rank the potential hazards that exist in your business, and understand and review your business’s existing OSHA health & safety programs. COVID-19 has brought a new emphasis on the need for businesses to have Pandemic Response Plans. RHP will evaluate your chemical inventories, hazardous waste storage, Safety Data Sheets (SDSs), training and employee exposure records, and measure against OSHA regulations for compliance. A gap analysis is performed to identify areas that are deficient, and RHP will provide recommendations and solutions for returning to compliance and for compliance maintenance. Our OSHA Audit reporting includes photographs of findings (the area or item of non-compliance), a hazard risk ranking, and recommended solutions for compliance. Findings are color coded and reported indicating most severe to minimal severity.

After the OSHA Compliance Audit Site Assessment

Following an RHP OSHA Audit, our professionals can provide additional support to remediate findings and perform a follow-up auditing to document the changes.

These services may include designing and drafting site-specific OSHA health & safety programs, customized employee training materials within-person or online training modules, performing employee exposure assessments,  and assessing building ventilation and validation.

If desired, RHP professionals may act as a business representative during an inspection and may assist in responding to OSHA complaints or inspections.  Generally, OSHA complaints and inspection findings or violations require some sort of remediation action on the part of an employer.  Sometimes the actions taken in response can lead to a case closure without a fine, or fines are dismissed or lowered.  RHP professionals understand what actions OSHA requires for remediation, and can perform the necessary remediation actions and provide the required detailed documentation.

Contact Us For An OSHA Compliance Audit Today

Workplace compliance for business owners under OSHA’s regulations can be formidable and stressful to navigate due complex requirements.

Contact RHP professionals who have decades of experience reviewing and understanding OSHA regulations, and helping clients bring their businesses into compliance through our comprehensive OSHA site audits to identify compliance gaps and provide solutions.

Additionally, RHP professionals provide follow on support after an event or OSHA complaint, inspection, or violation to help respond and mitigate your business and financial risks.

For further references and RHP White Papers on the topic, see: rhprisk.com/white-papers