How to Prepare for an OSHA Visit

Terry Jo Gile, MT(ASCP)MA Ed.

The Safety Lady®

It’s a typical day in the lab.  You come to work and settle into your desk chair when there is a knock on the door and the person standing in the doorway says, “Hi, I’m from OSHA and I’m here to help you”.  Before you panic and make a wrong move consider the following points:

·       Take the Compliance Officer directly to the CEO’s office for verification of his/her credentials and review the complaint.  The name and title of the complainant will not be revealed in the document.

·       Gather the managers and supervisors over the involved area to attend the opening conference and take lots of notes. 

·       Follow the Compliance Officer throughout the walkthrough and record any deficiencies identified.  Make sure the walkthrough only covers areas cited in the complaint.

·       Provide personal protective equipment (lab coat, gloves, etc.) before entering the testing area – failure to do so is an automatic violation with a potential fine up to $7,000

·       Take photos or video of any photos or video taken by the Compliance Officer.  This will help when it comes to abatement or fixing the citations.

·       If something that is cited can be fixed before the Compliance Officer departs, then do so.  This is called a “Quick Fix” and may still be cited but no fine should be levied.

·       Don’t volunteer any information – everything said and done is “on the record”.

·       Provide employees time to speak privately with the Compliance Officer.  He/she will give you a list of names or job titles to be interviewed – one of whom will be the complainant.  Most interviews will be 15-20 minutes for each employee with 6-8 employees being selected for interview. 

·       Attend the closing conference and take lots of notes.

·       Ask questions about any citations

·       Clarify the requirements for abatement of the citation

·       When the citations arrive, post copies at the site of the violation for 3 days or until they are fixed.

·       Prepare position on each citation and backup documentation as necessary

·       Attorney involvement should occur before the paperwork is submitted to OSHA and to assist with negotiation of the fines.

·       Most of all, make sure your employees know the OSHA requirements and are able to recite them when asked.  This includes policies and procedures on bloodborne pathogens, chemical hygiene, environmental monitoring (if applicable) and injury prevention.