In March, the Occupational Safety and Health Administration (OSHA) issued a new Field Operations Manual for its inspectors. What’s in the manual presents a good guide to employers about what to expect during an OSHA safety inspection.
OSHA could pop in on you because of an accident or just because your number happened to come up. An inspector who does show up is paying particular attention to two details that are highlighted in the Field Operations Manual (FOM):
- Recordkeeping. The FOM states that at the start of each inspection, an OSHA compliance officer must review an employer’s injury and illness logs for the three prior calendar years. Compliance officers are instructed to do this for all general industry, construction, maritime, and agriculture inspections and investigations. While a review of records at the start of an inspection used to be common, it’s now a requirement and a key part of every inspection. So the time is now to review your company’s recordkeeping practices and logs to ensure that they are accurate and up to date — before OSHA shows up.
- Hazards. The new FOM also provides more detail on OSHA’s use of the General Duty Clause, which requires all employers to maintain a workplace free from recognized, serious hazards. To hit you with a General Duty Clause violation, an inspector must first show that you recognized the hazard involved. The FOM provides an expansive list of the types of documents that signify an employer’s awareness of the problem, including company memorandums, safety work rules and manuals, workers’ compensation reports and manufacturers’ warnings. When employers identify hazards through these or other means, they must take steps to address the hazards, if feasible, or risk an OSHA General Duty Clause citation.
