How to Prepare for an OSHA Inspection

OSHA inspections within the healthcare industry are on the rise. Considering that the industry regularly interfaces with infectious materials, and handles patients in need of medical care, this is not much of a surprise. As an employer, it is a wise move to know what triggers an inspection, and how you can best prepare your facility for the event. Doing so will help you save time and resources, as well as help you avoid unnecessary OSHA fines and penalties, which can amount up to as much as $70,000 depending on the severity of the violation. Here is what you need to know:

What Triggers an Inspection?

In order to prepare for an inspection, it is helpful to know what triggers an inspection. Although many inspections arise due to employee complaints or reported incidents, there are other triggers. These include:

• Targeted Selection: As determined by OSHA, certain industries yield a higher proportion of workplace injuries than others. Healthcare happens to be one of these industries. When selecting targeted inspections for the industry, an OSHA officer will select several employers within a specific Standard Industrial Classification (SIC) code for an inspection. The officer will then arrive at the employer’s location for an unannounced inspection.
• Random Selection: OSHA performs many inspections on a random basis. With this process, OSHA will choose a business location based on random SIC selection.
• Employee Complaint: Employees have the right to anonymously report a complaint to OSHA. If an employee makes a complaint to OSHA about your workplace location, OSHA has the obligation to determine the validity of the complaint by performing an inspection.
• Workplace Injury: By law, if your workplace has encountered one fatality, or at least three employees have been hospitalized as a result of an occupational accident, you must report to OSHA within eight hours. Upon receiving a report, OSHA is obligated to visit your facility within 24 hours.
• Media: Since OSHA is a political entity, OSHA administrators feel obligated to address workplace incidents that receive press coverage in the community. If your location has received press in regards to a health or safety concern, it is wise to plan for an OSHA visit.

1. Action Plan. To ease the inspection process, make sure you have an action plan in place. This would include assigning an OSH officer, verifying all your recordkeeping efforts are up to date, ensuring your hazard communication program is displayed in a workplace common area, making sure you are in compliance with OSHA posting requirements, and ensuring that all other required policies are in place. OSHA will request written copies of all pertinent documents and forms, so make sure you have everything prepared.
2. Designate an OSH Officer. Make sure you assign a designated OSH Officer. In the event of inspection, you only want a single, trained individual to handle all correspondence with OSHA, and ensure proper execution of the action plan: This includes verbal communications with OSHA, preparation of written documents, accompanying the OSHA officer through the walk-though, and so forth.
3. OSHA Posters. Every employer is required to post OSHA’s Job Safety and Health: It's the Law poster. In addition, employers must post the OSHA 300A from February 1st through April 30th every year. To assist employers with this requirement, the LaborLawCenter™ offers the OSHA Safety Communication Poster: This poster contains the OSHA Job Safety and Health: It’s the Law poster, and the required OSHA Log 300A on a single poster. If you have Spanish-speaking employees, you will need to post OSHA requirements in both Spanish in addition to English.
4. OSHA Recordkeeping. An inspector will request multiple documents, so make sure your recordkeeping is up-to-date. Items an inspector is likely to request include forms and records such as: OSHA Log 300 and the associated OSHA 101 form, Material Safety Data Sheets (MSDS), training records, and a blueprint of the facility. In addition, the inspector will likely request company programs and policies, including: ergonomic standards, blood pathogens, needle-stick, injury and illness prevention plan, respiratory protection plan, hearing conservation program, hazard communication program, LOTO procedures, and the emergency and fire plans.
   
   Note that not all documents may be required for your facility. Before an inspector visits your location, make sure you do your research and determine which documents are required for your location.
5. Plan inspection route. In some cases, especially if OSHA is visiting to see a specific area within your facility, it may make sense to choose the inspector’s route ahead of time. Even though an inspector has the right to access any part of your facility, selecting a route ultimately gives you more control over the inspection process.
6. Housekeeping. It is a good idea to perform some housekeeping tasks around your facility. Make sure that all workplace areas are free and clear of unnecessary debris and clutter: especially areas along side the route you have selected for the inspector.

Overview

In general, if your location is subject to an OSHA inspection you will usually have less than 24 hours to prepare. Although some items may take minutes to prepare, save yourself the pain and frustration of waiting until the last minute: the best preparation you can make is to enforce OSHA standards in your facility at all times. Remember that OSHA’s primary purpose when conducting inspections is to gather evidence of violations. Proper preparation gives you greater control over the inspection process, and limits your exposure to costly fines, penalties, and legal issues. If your facility maintains ongoing compliance with OSHA requirements, you should have nothing to fear when OSHA comes knocking at your door.

This article is not designed to infer legal counsel, but is rather an informative guideline as to what healthcare employers can do to best prepare for an OSHA inspection.

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