The American Safety Training course, "Essentials of Safety Training I," says the kit should include these items:
- Paper and pens for documentation
- Tape recorder for documentation, with tapes and batteries
- Disposable camera for documentation, with film
- Flashlight for nooks and crannies
- Tape measure for measurements
- Tote bag to carry inspection materials
- Any other items specific to your company
- Locations of air-quality monitoring and noise monitoring equipment
According to Benjamin Mangan, president and founder of MANCOMM and American Safety Training (www.mancomm.com), "The kit should include a 'who to call' list for when an inspector appears. Inspectors can wait up to 45 minutes for a specific company official to show up." And, he said, "The kit should also include extra EXIT signs and DANGER: DO NOT USE tags. Be willing to fix problems on the spot, if possible."
Inspection Procedures
In the event of an inspection, the company recommends, the inspector should be led to a waiting area while company officials are notified of his/her arrival. If the company has a union, the representative must be permitted to be involved in the inspection.
Employers should centralize all pertinent information, such as training documents and 300 Logs for injuries and illnesses, so they can be accessed easily. Sources of confidential information should be identified to the inspector. Otherwise, the information will become public record.
Opening Conference
The inspector should explain why the establishment was selected for inspection. Employers should insist on seeing credentials, establish whether the inspector has a warrant and determine which documents the inspector wishes to review.
Walkthrough Inspection
The inspector, accompanied by the employee representative (if applicable) and employer representative, will proceed through the facility, inspecting work areas for potentially hazardous working conditions. The inspector should not be allowed to conduct the walkthrough alone. The inspector will discuss possible corrective actions with the employer representative, who should take notes on what is seen and discussed, what samples and/or pictures are taken, and what documents are reviewed.
Closing Conference
After the walkthrough, the OSHA inspector will discuss all hazardous conditions with the employer, indicating all citations that may be recommended. He should explain the appeal rights and procedures for contesting citations, and inform the employer of obligations regarding any citations issued. Employers should provide additional relevant information and request a receipt for any documents provided. They should neither make admissions of guilt nor argue their case with the inspector. The should also know the Miranda rights and keep answers to a simple "yes" or "no."