Q. OSHA seems to inspect our facility every year or so. How can I minimize the frequency of inspections?—F.J.
A. Do you have an updated safety program, and are your employees following it? OSHA inspects for a variety of reasons, including if the company has not been inspected for a while, has had violations in the past, there is a complaint, there are a high number of accidents or there was a fatality.
To decrease the chance of an OSHA inspection, have a good safety program and follow it. Often, companies have great written safety programs that they spent considerable time drafting (usually after an OSHA inspection), and then the program sits in a drawer. A paper program is insufficient. The safety program needs to be part of the company work practices and culture. The workers need to be familiar with it. The program needs the support and oversight of top management. Further, someone needs to be responsible for the day-to-day implementation of the program. It needs to be reviewed regularly and change as the company changes, with a watchful eye on how to prevent accidents.
One important element of the safety program is training. This could be through a variety of different methods, from a walk-around to on-the-job training. Regular safety meetings go a long way. Certain training and written programs are required under the various OSHA programs, including lockout/tagout, confined space, hazardous communications, protective equipment, hearing protection, etc. Remember to keep track of all training, including whether it was walk-around training, in a staff meeting or on-the-job training; who attended; and the exact training provided. It is good practice (and in some cases required) to draft an agenda before the training sessions, distribute the agenda, and have all attendees sign in at the training with their full name and title. The company should keep the job description for each job title in its files on site.
Another important factor for a safety program is worker input. Your program should have a mechanism for your workers to suggest ideas and report safety issues (without fear of retribution). Some companies have regular safety meetings to discuss ways to improve, or they routinely bring in a consultant to conduct an investigation and provide suggestions. Whatever course(s) your company takes, remember to determine if the changes made or the actions taken require you to update your safety program and/or train your workers.
A safety program is no assurance that OSHA will inspect your facility less frequently. However, the program goes a long way to reduce accidents, worker complaints and violations, and to comply with OSHA regulations—all of which should lead to a reduced need for OSHA to inspect your facility.