On Monday, we took a closer look at the first few steps of an on-site OSHA visit, including the opening conference and records review. (Refresh your memory on that post here.) As a new plant safety manager, being prepared in a situation like this is key, and we want to make sure you have the tools and information you need.
Now let’s take a look at the remaining two portions of the visit—the walk-around inspection and the closing conference.
If the inspection is a programmed inspection, the objective of the walk-around inspection is to ascertain if the facility is complying with OSHA standards. Ensure that your pre-designated team accompanies the inspector at all times, as the CO should never be allowed to walk the facility alone.
Keep detailed notes about the plant areas toured, equipment viewed, and comments made by the CO. If the CO asks questions, answer the question honestly, but do not admit you are aware of an unsafe condition or a violation. Team members should take photographs or video from the exact location the CO takes photos or video.
If OSHA’s visit has been triggered by an employee complaint, the CO should be escorted to the area where the complaint arose by taking the most direct route, to avoid line-of-site violations. Remember to keep the CO focused on the specific complaint.
OSHA has the right to interview employees during the inspection process. The employer representative cannot listen to the interview; the employer does have the right to ask what was discussed, but answers are voluntary. A list of the names of any non-management employees interviewed should be created. Video or audio recording the interviewmade by the CO is allowed only withconsent of the employee.
Management employees may be interviewed and the company has the right to have a representative present during the interview.
Upon completion of the inspection, the CO will hold a closing conference. The team that participated in the walk-around inspection should be present at this time.
During the closing conference, the CO will advise the team of all conditions and practices which may constitute a violation.You should expect the specific section or sections of the standard which may have been violated to be identified. The CO does not have the authority to issue citations or penalties-- authority for issuing citations and proposed penalties rests with the Area Director or a representative.
During the closing conference, the CO will obtain from the employer an estimate of the time required to abate the alleged violation(s) and take such estimate into consideration when recommending a time for abatement.
Keep in mind, the closing conference is not the time to disagree or debate the proposed citations…this is the time to listen. Statements made by the company representative during the closing conference may affect the decision regarding whether to issue a citation, as well as the characterization of the citationand the extent of the proposed penalty.
You may ask a question for clarification but do not argue with the CO. If there is a factual misstatement, the company representative should politely clarify. The CO will use the closing conference to explain contest procedures and provide an estimated timeframe of when to expect the results of the inspection.
Ensure detailed notesof all discussions during the closing conference are taken and retained for future use. Most importantly, after the CO leaves the facility, provide an update to your Corporate Safety Department.
Vote of Confidence
Congratulations! You’ve made it through your first OSHA visit. Knowing what to do when OSHA arrivesis a big step as you progress in your role as the new plant safety manager.
Download our complete guide for
new plant safety managers here.
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