Handling inspections: tips from insiders - includes related article on inspection tips - Occupational Safety and Health Administration inspections - Cover Story

HR Magazine, Oct, 1999 by Robert J. Grossman

Experts and those who have been there share tips on surviving a visit from OSHA.

Fear of the Occupational Safety and Health Administration (OSHA) doesn't have to paralyze you when an inspector turns up at your worksite. Plenty of employers have survived OSHA inspections, and some of those survivors are willing to share their insights and experiences to guide you through an impending inspection.

And you don't have to wait until you hear OSHA's footfalls on your front walk to start implementing that advice. There are many steps you can - and should - take immediately, before the first signs of trouble creep across your peephole.

Here then is a collection of tips - some you can use now, some you can use when OSHA officers show up - from those who have been there.

Develop a Team

If you want your organization to be prepared for OSHA inspections, assign an employee that task. "Appoint an OSHA coordinator," advises Neville C. Tompkins, SPHR, a consultant and author of A Manager's Guide to OSHA (Crisp Publications, Menlo Park, Calif., 1994). "Where there's no full-time manager, it could be the HR guy."

Your coordinator must know the business well, he says. In addition, the coordinator will need to assemble an OSHA team, which should "include the production manager, maintenance manager and the plant nurse who keeps the records."

Once the team has been assembled, hold a rehearsal of an inspection, suggests Tompkins.

Lawrence Halprin, an attorney with Keller and Heckman in Washington, D.C., also endorses rehearsals. "We have a former compliance officer who goes out and runs mock drills for our clients," he says. "We run it just like a fire drill."

Involve Employees

Employers and HE professionals should make sure that employees are ready for inspections. Start by preparing workers in advance for the possibility that OSHA officials may ask them questions.

"During orientation, explain that the company is subject to inspections by the government and an inspector may want to speak to you about your work here," Halprin advises. He says "Tell them, 'Our policy is to make you available voluntarily [meaning the company won't require OSHA to get a subpoena]. If you want to speak to an inspector by yourself or with your union rep, that's fine.'"

June Brothers, group director of HR in Atlanta for forest products company Georgia-Pacific Corp., says that getting employees involved in training is key. "Have them really involved in the safety program - helping you do the accident investigations, doing walk-around inspections, helping do job analysis," she says.

She also suggests offering "very specific safety training - not just showing folks a video. If you take that kind of proactive stance, you're probably not going to get complaints." Georgia-Pacific, which has 48,000 employees, averages four or five OSHA complaints a year.

John Kipta, area human resource manager for Reliant Building Products in Dallas, agrees that establishing a good training program is vital. "Look at your safety program the same way you would look at other HR training programs," he suggests. "In an average company, there's plenty of off-the-shelf programs. The problem is most of these are simply a video. Instead, you need to move to applied learning where the employee has to demonstrate a level of competence. Companies doing this find that when OSHA shows up, they're in better shape. The employees are educated; they know the processes."

Build Bridges to OSHA

Another smart preemptive step is to get to know your local OSHA compliance officers before problems arise; if they have confidence in your integrity, you'll be ahead of the game.

"You want to develop a relationship with the area office," says Eric Brett, corporate safety manager at Hitchiner Manufacturing, a metal casting firm in Milford, N.H. "We have a good comfort level, so now if there's a gray area, I don't hesitate to call them up for advice. And because they know us, when they receive a complaint, they follow up with a letter. Depending on our response, if they like the way we abated the problem, they won't come on site."

Brothers takes a similar approach. "We try to develop a partnership, a working relationship with OSHA. It can be as simple as dropping by the local office, picking up materials, asking them questions. A lot of people are afraid to ask OSHA a question, thinking if they do [OSHA] will descend on them. It doesn't happen that way. They'll give you the information and at the same time it will help you develop a working relationship so OSHA knows you're trying to do the right thing."

Patrick Kapust agrees. Kapust served as an OSHA compliance officer for eight years before recently becoming a safety and occupational health specialist in OSHA's Office of General Industry Compliance Assistance in Washington, D.C. "If someone calls up with a question, we're going to try to answer it. We don't go out there; our goal is to reduce hazards, not issue citations. It's better for us if we can take care of it on the phone."