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Don’t be Unprepared for an OSHA Inspection YOUR COMPANY SHOULD ALWAYS BE PREPARED FOR A SURPRISE VISIT FROM OSHA. DAVID A. WARD SR. AND JACK RUBINGER For the thousands of companies that have been through an OSHA inspection since OSHA’s inception in 1971, the experience has ranged from scary and nerve wracking to polite and professional. Each inspector typically has pet peeves based on past experience. Some are sticklers for electrical issues. Some are hyper aware of power tools. You actually can learn a lot about cooperation and collaboration through the experience. Having said that, there’s always a looming fear of discovery and paranoia surrounding an impending OSHA inspection – much like the fear and nervousness we face when we’re dealing with an IRS audit. In both cases, your company should always be prepared for a surprise visit. Given the fact that OSHA fines increased in some cases by about 80 percent in August – the first penalty increase since 1990 – that fear and paranoia is liable to escalate, but there are preparatory steps that can be taken to minimize the fear of discovery. Having the right attitude, understanding and expectation about an OSHA inspection is important. When supervisors demonstrate their commitment to safety by holding employees accountable for their actions, it makes safety a priority and not just another program. This perception of how safety is managed creates a positive attitude and sense of genuine concern – especially among new employees. Providing employees with a variety of activities like tool box talks, involvement in accident investigations, participation in safety committees, engagement in weekly and/or monthly inspections and assuming roles of responsibility, changes the focus from “them” to “us.” OSHA inspectors notice that attitude and employee involvement. grams like lockout/tagout, GHS, machine guarding and fall protection. Preparation could result in a reduced number of potential violations that could add up to hundreds of thousands of dollars. While we can’t delay or prevent OSHA from increasing their penalties and the surrounding fears these penalties create, we can all do a better job of understanding our roles, getting up to speed on current safety programs like lockout/tagout, and putting ourselves in the shoes of the OSHA inspector. David A. Ward Sr. is a former federal investigator for OSHA and is president of Safety By Design Consultant Services, which runs a program called “Preparation O” specifically to address concerns about OSHA and prepare companies for the unexpected OSHA visit. Jack Rubinger is a frequent contributor to industrial, workplace safety and manufacturing publications. PREPARATION IS KEY Communications in regards to safety should be delivered directly from the CEO to every staff member and not be diluted by other department heads who do not manage this critical component of every company – big or small. We’ve discovered that most companies really are unaware of their roles, administrative responsibilities and the significant deficiencies in their safety pro- Building Entrepreneur | 11
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