It's a normal Tuesday at your facility - operations are running smooth, everyone's on the floor that needs to be, and you're feeling pretty good. Suddenly, your sense of normalcy is turned on its head when OSHA walks through your door.
All confidence in your facility's compliance evaporates inside you. You're suddenly seeing every little thing that could be considered a violation, and it's too late to do anything about it.
OSHA popping by is one of those things that only happens to other people - until it's suddenly happening to you. At KP, we know this because we've seen it with our clients.
If you aren't prepared, you could find yourself packing up and moving operations, or weighed down by significant fines.
It's important to keep everything in your facility up to standards, and we wanted to give you a quick rundown of what to expect when OSHA knocks on your door.
Here are a few places they'll always check, so you can make sure you're not on the wrong end of an expensive OSHA inspection.
1. They'll interview your employees.
People are people. One thing that is guaranteed to happen at almost every single workplace no matter the environment is that as people get more comfortable in their work area and with their job, even the biggest sticklers might loosen up on some of the details.
When an OSHA inspector visits your facility, one of the biggest items they'll cover on their walk-through of your facility is employee interviews.
It's important to remember that while they're looking at safety signage and the state of machines, they'll also be watching your employees as they conduct themselves normally. They'll take this time to ask your employees questions, primarily about their role and the training they received. They'll be looking to verify that your employees have received adequate training, and to determine if there are discrepancies between what management says the standards are and what the employees actually carry out.
One way to figure out if there might be issues between what you think an employee knows versus what they actually know is to shadow them, and ask them the sorts of questions an OSHA inspector might. Not only will this give you insight to what your employees are up-to-date on, it will likely illuminate areas that need further training, or at least a refresher. This exercise will ensure you're prepared for anything, and allow for growth opportunities when it comes to training.
2. They'll look at your signage.
Signage indicating important information such as warnings on dangerous areas of the warehouse, notices about out-of-order machinery, or signs indicating hazardous materials are going to be checked during an inspection.
When you're working in the facility every single day, these things can fade into the background and make you less likely to notice things changing or not being up to code. Staying up on regulations is about more than just making sure the right signs are up; they need to be current, visible, relevant, and legible.
Regular auditing of the state of signage in your facility is crucial to being prepared for a surprise OSHA inspection. Check that all signs are properly installed, uncovered, and are up to date.
In certain kinds of facilities, signs can get covered with residue that might cover up vital information, or might be faded with time. Signs can get worn out over time or get dirty or scuffed due to the work being done at the facility. Make sure that all signs are clear and can be read by employees from some distance. Do a run through of all the areas in your warehouse that might have a hazard. Check that there is appropriate safety signage everywhere and that it is easily read from the distance required by OSHA regulations.
3. They'll investigate your machine operations.
When OSHA comes to inspect a warehouse, you can guarantee that they'll be paying special attention to the safety surrounding machine operation at any given facility. They'll be looking for safe operation of the machinery as well as the operational integrity of the machines used on the floor. Concerning machine safety, here are a few big areas an OSHA inspector will be checking:
Machine Guarding - OSHA's Machine Guarding Standards require that machinery is equipped with appropriate guards to protect operators from points of operation, ingoing nip points, rotating parts, and flying chips and sparks.
Operator Safety - Ensure that all personnel operating the machinery are authorized to do so. The last thing you want during an OSHA inspection is an employee operating dangerous machinery who shouldn't be. At this time they'll also be checking that other guidelines are being adhered to, like speed limits and load handling.
Maintenance Records - Inspectors will verify that the machines are regularly and properly maintained, as malfunctioning equipment can pose significant risks. Training and certification records will be reviewed to ensure that operators are qualified and knowledgeable about safe operating procedures.
Personal Protective Equipment (PPE) - While PPE is not about machines specifically, while investigating the safety of machine operations at your facility, an inspector would also be paying special attention to whether both the operator of the machine and those who must come into close contact with it on a regular basis are wearing the proper protective equipment.
Lockout/Tagout Procedures - As inspectors check how safely your employees are operating the machinery in your facility, they'll also be checking that lockout/tagout procedures are in place and being followed. While you ideally won't have a machine that needs to be shut down during an inspection, you'll want to make sure you have all the necessary equipment and procedures ready to show you'll be ready if it's needed.
4. They'll dig through records.
OSHA will show up unannounced for a variety of reasons - some of these include employee complaints, or an uptick in reported injuries on-site at your facility. Regardless of the instigating factor, they'll be sure to check whether you've been keeping up with your records.
Should an inspection take place, they'll be digging through reports to make sure everything is up to standard. It's important to be organized and diligent about keeping up with this sort of documentation at all times so you aren't left unprepared.
What documentation will be needed for inspection will depend on the facility - both what sorts of machines are present and what materials are being handled. Here are a few kinds of documentation an inspector could check for:
- Injury and illness logs
- Safety training records
- Maintenance and inspection logs
- Hazard assessments
- Emergency action plans
- Lockout/Tagout (LOTO) procedures
- PPE records
- Exposure monitoring records
What you might not expect from an OSHA inspection (From an HR Professional)
While you can prepare the best that you can for an OSHA inspection, there's probably something you'd never think about. We talked to KP Staffing's own HR Manager, Tiffany Cohen, about an experience she had when one of our clients had an OSHA inspection. While she said that most of the process was fairly understandable, one thing took her by surprise.
The case by case nature of violations. When it comes to OSHA, sometimes you don't have a violation on your hands until you do. Our client hadn't done anything wrong by having a particular type of press machine as far as OSHA goes. Everything was up to code. But when an injury occurred on their site and an inspector came, the fact the injury happened caused the machine to be a violation.
"I think the only thing that surprised me was the fact that we got a massive fine for something that was technically not a violation," Tiffany said. "You can be considered violating something not necessarily because of what you were doing or what was in place, but just because an injury or incident happened."
There may be aspects of your warehouse that are not technically violations, but if while the inspection is happening associates are misusing or not adhering to processes correctly, you'll still get a violation and a fine.
Here's how you can stay prepared.
The best way to get through a surprise OSHA inspection is to always be prepared. That's easier said than done, so here's a recap of some of the ways you can make sure your facility is always ready:
- Create a checklist and conduct your own audits. Whether it's monthly, quarterly, or yearly, walk through your warehouse like you were an OSHA inspector. Look for every little thing that could possible be a regulation violation.
- Evaluate employee training and knowledge, and supplement where needed. Talk to your employees and see if the safety training they receive is adequate to them. Interview them as they do their every day work to find gaps in knowledge where you can improve your safety training to ensure a safe work environment for all employees.
- Conduct regular documentation checks. The worst time to find out your records haven't been kept properly is when an inspector is rifling through them. Like your warehouse audit, do regular audits of your records and make sure everything is as it needs to be.
- Get an outside pair of eyes. It might be a manager at a different facility or a subject matter expert you bring in as a consultant - sometimes what's needed to see holes in safety protocols is a fresh perspective. Have someone who isn't as familiar with your facility (but is familiar with safety procedures) do a look through to see if they catch anything you might miss.
By taking these steps and remaining up-to-date on the changing safety regulations, you can rest easy knowing you've done everything you can if an OSHA inspector visits.
And remember - compliance is about more than being prepared on the chance OSHA stops by. Keeping up with everything an inspector might check will not only protect you from fines due to violations; it will keep your facility and the people who work there safer, year-round.