Know what OSHA wants before OSHA even arrives

COLUMBUS, Ohio—Preparation and knowledge of your company's past safety issues are important to know before the Occupational Safety and Health Administration shows up at your factory, Chris Whitehorne said at the Environmental Health and Safety Summit.

"Before you have OSHA knocking on your door, you want to be prepared in advance. Most importantly, know your risks and address them. I think everybody in this room knows the top three concerns that they have at their facility," said Whitehorne, director of health and safety with U.S. Compliance, an environmental health and safety firm in Excelsior, Minn.

He said it's a good idea to identify the top three to five concerns and work on fixing them.

Whitehorne recommended knowing the company's history with OSHA and checking the agency's website, where you can search all factory locations and see any citations. Pay special attention to repeat violations.

"Have there been inspections in the past at your facility? Do you know what sites have had past violations? And most importantly, do you understand and make sure your facility has addressed them and responded to them correctly?" he asked.

Employee complaints are the most common trigger for an OSHA inspection, if OSHA determines workers are in imminent danger, Whitehorne said.

"So, in terms of employee complaints, one of the biggest things to really eliminate the potential for OSHA visiting is to address your employee's concerns. That's what it comes down to," he said. "Do you know what their concerns are? Do they have complaints? If they're voicing them, are you tracking them? Are you addressing them in a timely manner?

"Those are really critical items. A lot of times. when we see these complaint inspections, what's occurring is they've been brought up by the safety committee. They've been brought to the supervisor, and they've fallen on deaf ears. Nobody responds to them. Eventually they come to a point where they're so disgruntled—concerned, really, about their own health and safety—that they notify OSHA."

Whitehorne said better communication is important: "The biggest thing you can do is make sure you have systems in place for employees to voice their concerns, and make sure you actively respond to those."

Company safety officials also should check OSHA's national and local emphasis programs. Whitehorne said, there are nine national areas, including hazardous machinery and amputations. He said OSHA can look up your company's SIC code, then come by for an inspection on those areas. That means companies should look at these areas in advance. Lockout/tag-out and machine guarding are another common area for inspections.

Another recommendation is to eliminate or control "red flags" ahead of time.

"Most of the time, when OSHA comes on site, if there's good housekeeping, there's proper lighting, clear aisles, clear access to all your emergency equipment and overall the facility's in good condition; That goes a long way to an inspector. That first impression's pretty critical. If they walk out in the facility and there's forklifts parked in the aisle in front of a fire extinguisher, there's oil on the floor, and it's just a total mess? Obviously, they sharpen their pencils a little bit as they start digging deeper in those areas," Whitehorne said.

When OSHA does come knocking, "get ahead of the game," he said. Make sure the front desk receptionist knows who to notify—and doesn't let the inspector in before the right person shows up. Make sure your key contact people have backups, in case somebody is on vacation with OSHA arrives.

Make sure important records are quickly available. And Whitehorne said company leaders should know why OSHA is on site and bring the inspector to just the specific areas of concern—even if that means walking around the outside of the building to get to the warehouse to check out a complaint about forklift traffic there. You don't need to go through the production area.

"Just be aware, even if OSHA comes on site for an employee complaint, or an emphasis program, they can extend the scope if they see open and obvious safety concerns," he said. Accompany the inspector at all times, take good notes and shoot the exact same photos the inspector does.

Fixing things right away, like a blocked fire extinguisher, can show good faith and may avoid a fine, he said.

Answer questions directly, Whitehorne said, but don't guess at information or give estimates.

"You can provide that information later if they request it," he said.