Industrial Hygiene is about forecasting the risks that workers may face on the job, finding and analyzing potential issues, and preparing for ways to control hazardous exposure. Employers are required to ensure the safety of their workers in accordance with OSHA standards (as well as any other applicable state or federal laws). To ensure this, OSHA performs inspections to enforce their standards, all with the same purpose as Industrial Hygiene: to protect the health and safety of American employees.
In the prior three blogs of this series, we discussed Industrial Hygiene as it relates to silica, noise, and exposure monitoring. For this blog, we are going to review OSHA Inspections.
OSHA gives priority to the riskiest workplaces: those that pose a high level of danger for serious injuries or death. Whenever there is a death, the employer must report within 8 hours so that OSHA can help protect other workers. Similarly, injuries requiring hospitalization must be reported within 24 hours. Any complaints to OSHA made by workers require immediate attention, and reports made by other entities are taken seriously. Targeted inspections, particularly within industries that have elevated hazardous conditions or have had higher rates of illnesses or injury, are also conducted. Additionally, follow-up inspections will occur, in certain conditions, to check for appropriate solutions following a previous citation.
With permission of the complainant (who can remain anonymous), OSHA will call employers regarding lower priority hazards to explain the health and safety concern and follow up in writing. The employer must then respond within 5 working days in writing to explain how the situation has been solved. If the complainant is satisfied and the response is adequate, an on-site visit will generally not be needed.
OSHA does not have to provide notice in advance when they decide to do an inspection of a worksite, although employers do have a right to insist on an inspection warrant before allowing an inspector on the premises.
OSHA compliance officers prepare themselves in advance of an inspection by reviewing a worksite’s history with OSHA, the processes being used by the industry, and the OSHA standards most likely to apply. They arm themselves with personal protective equipment (PPE) and bring what they need to conduct onsite testing.
When they arrive, the officers must present their credentials and conduct an opening conference. During this time, they spell out why they are there, the scope of the inspection, and the procedures for the walkaround. They also discuss which employees will be involved and their plans for employee interviews. The employer designates a staff member to accompany the inspector and has the right to have an authorized representative in attendance. During the walkaround, the inspector goes to the in-scope locations of the work site and checks for hazards, pointing out any apparent violations. They review records regarding worksite illness and injury and look for the required official OSHA poster, all the while keeping trade secrets confidential and keeping work interruptions to a minimum. Afterwards, the inspector reviews their findings with the employer and their representatives, discusses actions that can be taken to resolve issues, explains citations and proposed penalties, employee rights, and how the employer can contest the findings. Usually, OSHA will allow a penalty reduction if the employer is acting in good faith.
How to Prepare
It is never convenient to have an OSHA inspector appear, yet if your worksite has a higher-than-average potential for injury or illness, it is only a matter of time. One good way to prepare, is to conduct a mock audit by a certified industrial hygienist and/or a certified safety professional. Prevention is the best medicine; identifying your regulatory needs and coming into compliance before an accident and before OSHA arrives will help you avoid unplanned costs, schedule slow-downs, and more importantly, help keep workers safer.
In the event of an OSHA visit, a certified industrial hygienist can be your authorized representative, helping you every step of the way during an audit.
At RPF Environmental, we support our customers with a variety of industrial hygiene services related to OSHA compliance. We have over 30 years of practice with regulatory compliance, safety reviews, mock OSHA inspections, process safety management, and more.
Industrial Hygiene: It’s All About Worker Health and Safety
Stay tuned for the more information about industrial hygiene services in the last part of this series!
Call us at 603-942-5432 today to find out how we can support your industrial hygiene control program.