Are you worried about the possibility of OSHA showing up for a surprise inspection? Are you not exactly sure what to do about that and how to get prepared? If so, you’ve come to the right place.
Triggers are not random events and do not happen by accident. There are very specific triggers that you need to be aware of that prompt safety inspections. A lot of these triggers are caused by deficiencies and mistakes made within your own company. Being aware of these triggers, and more importantly, how to prevent them, can reduce the chance of ever getting inspected to begin with.
Inspection Scopes
Before getting into the inspection triggers themselves, it’s important to understand that the trigger often, but not always, will determine the scope of the inspection that is likely to follow. In other words, how broad the scope is going to be. The broader the scope, the greater the chances of more violations and fines.
Focused
A focused inspection is typically limited to a very specific health or safety hazard or maybe a few hazards. These are usually associated with an employee complaint or a drive by. If you do get inspected, you want it to be a focused inspection because it is so limited.
Comprehensive
A comprehensive inspection includes ALL areas of your safety program. It is literally going to evaluate and scrutinize all areas of your required health and safety programs, including a detailed inspection of your facility that can last for days or even weeks, along with all of your written programs and safety training program and records. If you don’t have everything in order and up to date, comprehensive inspections will result in the highest number of violations and fines, often exceeding $100,000 or more.
Expanded
Expanded inspections usually begin as a focused inspection, but expand into something much more comprehensive. This normally happens when the OSHA inspector notices other violations during the inspection, or if the company exhibits a bad attitude towards safety.
Specific Triggers
- Employee Complaints
Employee complaints are by far the number one trigger and account for about 25% of inspections. This can be a current employee or a past employee that you laid off or fired all the way up to six months ago. It’s an important reminder of making safety a priority at your company so your employees know that you take it seriously and won’t turn you in.
- Serious Injury
When a serious injury or fatality happens in your facility, you must self-report to OSHA, typically within 24-hours, unless it is a fatality, in which case you have to report within 8-hours. Serious injuries include: an amputation, a loss of an eye, inpatient hospitalization at least overnight or fatality. Depending on the type of injury, OSHA is going to follow-up with either a call or a fax that requires a formal response from you within a certain deadline. If the injury is more severe, or if there’s a fatality, they will follow-up with a live inspection that could be focused or comprehensive depending on the severity of the injury and the circumstances.
- High Injury Rates
If you have 11 or more employees and are in manufacturing or another high hazard industry, you must complete OSHA 300 logs, which includes calculating your TRIR and your DART scores, which are your injury rates. Then you have to electronically submit them to OSHA. If your injury rates are high, this will put you on a targeted list for a comprehensive inspection. [] Before one of our current clients hired us, they had a DART score above 6.5 that put them on the targeted list, and OSHA was there for weeks, which resulted in a lot of fines and penalties.
- National Emphasis Programs (NEPs)
NEPs target high hazard industries or very specific hazards. This often results in a comprehensive inspection because OSHA knows that certain industries and hazards are going to result in imminent danger to the health and safety of employees.
- Referral Inspections
When police or EMS respond to an injury or fatality at a company, typical operating procedure is for them to contact the local OSHA office to let them know about what happened. This is a reminder about the importance of self-reporting serious injuries within that required time frame or you are going to be cited for failing to report. Failure to self-report is very common and a top violation.
Current OSHA National Emphasis Programs
- Primary metals
Primary metals can be everything from steel fabricators to foundries. Just about all the metals fabricators and manufacturers are already on this list.
- Combustible dust
If you’re dealing with wood or fiber, you have combustible dust, and will be on the targeted list.
- Hazardous machinery
They are looking at amputations. Just about any type of equipment in a manufacturing facility can result in amputations if you don’t have good machine guarding.
- Heat
Indoor and outdoor.
- Hexavalent Chrome, Lead or Silica
Exposure can result in very serious health hazards. Use in your environment will put you on the targeted list.
- Process Safety Management (PSM)
PSM usually applies to bigger manufacturing companies that have ammonia and bulk chemicals.
- Inspector Drive-Bys
This is when an inspector drives by a company and notices a serious violation going on in plain view. When this happens, they’ll pull into the company to start an inspection, which may or may not expand beyond the violation that they originally noticed.
- Follow-Up Inspections
If your company has already been inspected and cited for a violation, OSHA can return any time after that. [] If they find the same or similar violation that they’ve already cited, that can trigger either a willful or repeat violation that can run up to $152,000 [] So, if you get inspected and cited, you have got to stay on top of those violations to prevent them from happening again because there will be a follow-up inspection sooner or later.
I hope you learned a lot about OSHA Inspection triggers and can take action to prevent these triggers from happening at your company. Please post in the comments below if you’ve ever had one of these triggers happen to your company, how that inspection went for you. If you have any questions about this, I’ll definitely respond to any questions or comments that come up.
Special Offer
Are you and your company really ready if OSHA shows up tomorrow in your lobby for a surprise inspection?
The fact is, if you’re like most small manufacturing companies, the answer is probably no. And if that sounds like you, don’t feel bad, you’re not alone. The fact is that OSHA goes across the country every single day and hits small companies just like yours and issues all kinds of citations, fines and penalties that run into the tens or even hundreds of thousands of dollars. Could you really afford that?
The best preparation and the best way to pass an inspection is to know and have the confidence that you have a fully functioning OSHA compliant health and safety program.
To help those of you who are looking to be proactive and make sure that your safety program is up to date, I’m going to make 2 very special free no obligation offers to you to help get you on track if you don’t have a safety program right now.
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Here they are:
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Thanks for reading and we look forward to hearing from you soon!
