How an OSHA inspection actually begins

Hopefully, your company is prepared if OSHA arrives to conduct an inspection, but did you know the inspection begins before the inspector walks through your door?

When OSHA inspects an establishment, the Compliance Safety and Health Officer (CSHO) first looks into the company’s history. Red flags might include employee complaints, reports of serious injuries, or previous inspections that resulted in violations.

Upon arriving at the location, the CSHO will often look over the property from a public road or sidewalk, and even take photos of the buildings and grounds, before knocking on the door. They’ll look at the condition of the property or jobsite and make a note of whether the grounds, parking lots, sidewalks, and other areas are well-maintained. This gives the CSHO some insight on the company’s culture. If outdoor areas show a dedication to employee safety, then (hopefully) the indoor working areas will reflect that dedication.

In contrast, if the outdoor areas are poorly maintained (or if hazards are in plain view) the CSHO will expect similar problems indoors. At construction jobsites, most of the property (and workers) may be visible from a public area. The CSHO will look for housekeeping issues and watch how workers handle cranes and equipment, whether workers use fall protection, and look for other potential violations before entering the property to announce themselves.

After the knock

After knocking on the door or walking inside, the CSHO will present credentials and ask to speak with a person in charge. Since most companies have websites, the CSHO may have researched the company to find the names (and even photos) of company officers.

OSHA will allow up to one hour for the employer to make someone available (plant manager, safety director, etc.). If that person won’t be available, the CSHO may ask for another company officer, potentially asking for someone by name to begin the opening conference.

During the opening conference and walkthrough, the CSHO will ask a number of questions. Be aware that some questions may be open-ended, or the CSHO may allow for long (awkward) pauses, since quite a few employers will “overshare” information. Employers are advised to carefully consider their responses to any questions, and ask for clarification rather than providing information that wasn’t actually requested.