Hettrick, Cyr & Associates, Inc.

Outline of our simulated OSHA inspection services

In order to test OSHA compliance and be fully prepared for OSHA inspections, simulated (mock) OSHA inspections should be conducted periodically. These "dress rehearsal" inspections will acquaint management personnel with OSHA inspection procedures and should ensure compliance with OSHA regulations.

Due to potential regulatory sanctions provided by the OSHAct, it is important for your company to prepare for an OSHA inspection and know what to do should an inspection take place. The first step for preparation is to create an OSHA policy. The policy should include basic OSHA information, instructions on what management personnel should do if an inspection occurs and general OSHA standard compliance guidelines.

We recommend that two company representatives and alternates be selected prior to an inspection and trained on basic OSHA procedures and standards. The receptionist and all department management should be informed as to whom to contact when a representative from OSHA arrives. Managers should have information available which will provide answers to questions likely to arise during the inspection.

In addition, an employee representative is permitted by law to accompany the compliance safety and health officer (CSHO). The employee representative must be selected by the employees themselves or by the compliance officer. The employer is not permitted to select the employee representative. Where there is no authorized employee representative, the compliance officer can consult with a reasonable number of employees concerning safety and health matters in the workplace. These consultations may be held in private.

In order to prepare your company for a potential inspection and to determine compliance related to OSHA standards, the simulated OSHA inspections conducted by Hettrick, Cyr & Associates, Inc. will be procedurally based on the following services:

I. Opening Conference

During the opening conference, the occupational safety & health consultant from HC&A will explain the purpose of the visit, the scope of the inspection, and the standards that apply. In a real OSHA inspections, the employer is given copies of applicable safety and health standards as well as a copy of any employee complaint that may be involved. If the employee has so requested, his or her name will not be revealed.

Your company will then be asked to select employer representative(s) to accompany the safety consultant from HC&A. We suggest that your company designate two managers for this purpose. It is your option whether an employee representative should be present during this simulation. With your permission, we would like to question employees during the inspection tour process.

According to the OSHAct, CSHOs are instructed to take photographs as a means of documenting any alleged violation. The recent use of videos for the same purpose has not been contested successfully and would appear to be a legitimate avenue for the CSHO to document violations. During a real inspection, the CSHO will request permission to take pictures with the understanding that facility security, product liability, and trade secrets are kept confidential. You also have the right under the OSHAct to take duplicate photographs or ask for copies.

II. Records Review

Secondly, we will ask to review a number of records, programs, written procedures and related employee training records. The following list is an example of requested records. The specific records will depend of your industry:

OSHA Log 300
OSHA Form 301
Supervisors First Report of Injury or equivalent state form
Hazard Communications written program, list of chemicals, MSDS sheets, and employee training records
Medical records of employees exposed to toxic substances or harmful physical agents
Equipment safety inspection records (ladders, fire extinguishers, welding equipment, forklifts, hoists, respiratory equipment, etc.)
Written lockout/tagout procedures, inspection records of procedures, and employee training
Written emergency response procedures for hazardous substance spills
Employee safety training records
Fire protection programs
Emergency evacuation procedures and training
Sound level readings and annual audiograms, if applicable
Written respiratory protection procedures, if applicable
Written personal protective equipment program, hazardous assessment survey, PPE inventory records, and employee training
Confined space entry program, if applicable
Process Safety Management program, if applicable
Written Bloodborne Pathogens program, exposure control plan, and records of training

The records review process will focus on programs and procedures required under your operations.

III. Inspection Tour

Hettrick, Cyr & Associates, Inc. will conduct a facilities simulated OSHA inspection. Based on the OSHA guidelines all inspections will be a wall to wall.

During an OSHA inspection involving a complaint, the CSHO typically limits the inspection tour to the specific complaint. They will ask permission to conduct an expanded inspection if, in his/her review of records, there is evidence of numerous hazards or if violations are in plain view in other areas.

During the course of the simulated OSHA inspection, the HC&A consultant will point out any unsafe or unhealthy working conditions observed to the employer representatives.

Based on your operations, the following OSHA standards may apply to the facility inspection:

Machine guarding
Walking and working surfaces
Housekeeping
Aisles and passageways
Means of Egress
Electrical safe work practices
Flammable and combustible liquids/Spray Finishing
Hazardous waste operations
Noise exposure (No noise measurement to be conducted)
Air Contaminants (No air sampling to be conducted)
Fire extinguishers and inspection requirements
Powered Industrial vehicles
Compressed air
Hand and power tools
Welding and cutting operations
Process Safety Management

IV. Closing Conference

After the inspection tour has been completed, we will conduct a closing conference. This phase involves outlining to the company representatives those items which are believed to be alleged violations under the OSHAct. We will also outline other non-OSHA conditions that can lead to workers' compensation injuries and illnesses.

During this phase, Hettrick, Cyr & Associates, Inc. will also brief division personnel on process of citation issues, abatement periods, and the employer's right to appeal under the OSHAct.

A written report of alleged citations and possible fines will be generated within two weeks after completion of this project.

Cost of this service depends on the location and size of you operations.
Please contact Hettrick, Cyr & Associates, Inc. at (888) 806-0065 or e-mail us at info@hettrickcyr.com

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