Question

1. Describe the steps an employer should take when OSHA knocks on the door.

Answer 1

If an OSHA inspector knocks on the door the an employer should take the following steps :

1) Restrict admittance until management personnel are on site - Never allow the opening conference or the inspection process to commence until the appropriate pre established management persons are present.

2) Reason of inspection - an employer should always asked for the reason behind the inspection whether it is a complaint,fatality,targeted or media based inspection.

3) Distinguish whether the inspection is related to safety or industrial hygiene - If the OSHA officer is a safety specialist or compliance officer, the inspector will not conduct hygiene samplings. If the inspector is an industrial hygienist, it is likely that the inspection will focus on industrial hygiene issues such as noise monitoring, air sampling, etc. If possible, perform simultaneous sampling to verify OSHA results.

4) Designate an employee representative. OSHA inspectors are required to ask for the participation of an employee representative. If the plant is organized, the union safety chairman, shop steward or other union official will be asked to participate.If the facility is not organized, the employer may choose to have an employee representative participate if there is an employee safety committee.

5) Maintain records. Inspectors will routinely review the current and prior 3 years’ illness logs and annual summaries of injuries.They will check to ensure the OSHA poster is in place, as well as for the following programs: hazard communication, lockout,emergency evacuation and blood borne pathogens.

6) Protect trade secrets. OSHA is required to protect the confidentiality of any items which are asserted to be trade secrets. Verification of trade secrets should be done at the opening conference, and a follow-up letter asserting the trade secret nature of the processes or workplace should be sent to the OSHA area director.

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