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October 7, 2014

What to Expect During a Surprise OSHA Inspection

Few phrases get a manager’s heart pounding like “OSHA is here.” A surprise OSHA inspection can feel like an ambush, but it doesn’t have to be. If you’re prepared and know your rights, you can navigate the process professionally and calmly. This guide breaks down exactly what to expect, from the moment the inspector arrives to the closing conference.

What to expect during an OSHA inspection infographic

What to Expect During a Surprise OSHA Inspection

1. Arrival of the OSHA Inspector

OSHA inspections are almost always a surprise. The inspector (a CSHO, or Compliance Safety and Health Officer) will arrive at your front desk, never at the back door. They must present their official credentials, which include a photo and a serial number. You have the right to verify these credentials by calling your local OSHA office. Be professional and courteous, but do not start the inspection until you have confirmed they are who they say they are.

2. The Opening Conference

Once credentials are verified, the CSHO will hold an opening conference. This is not optional. They will explain *why* they are there. An OSHA inspection can be triggered by a specific complaint, a reported injury, a national emphasis program, or just a random selection. They will also outline the scope of the inspection (e.g., “just the warehouse” or “the entire facility”). You have the right to have a company representative (like a safety manager or executive) and an employee representative present.

3. Review of Relevant Documents

Before the walkaround, the inspector will ask to see your records. This is a critical part of the OSHA inspection. Be prepared to show your OSHA 300 Logs, your written safety programs (like Hazard Communication, Lockout/Tagout, etc.), and any relevant training records. Only provide the documents they ask for. Do not volunteer extra information.

4. The Walkthrough Inspection

This is the part everyone dreads, but it’s a fact-finding mission. The inspector will tour the areas included in the scope. They will observe work practices, check for hazards, and ensure equipment is safe. They *will* take photos, videos, and notes. Your company representative should accompany them at all times, take duplicate photos, and write down *everything* the inspector notes. Do not attempt to hide, fix, or clean up hazards in front of them.

5. Employee Interviews

The CSHO has the right to interview any non-management employee in private. This is a key part of their process. Management cannot be present, and you cannot retaliate against an employee for what they say. It’s a good idea to have your employees trained on their rights, including the right to have an employee representative with them if they choose.

6. The Closing Conference

After the walkaround and interviews, the inspector will hold a closing conference. This is your most important meeting. They will review all *apparent* violations they found. These are not final citations, but you should take them very seriously. Ask questions, understand what they saw, and discuss potential abatement (fix-it) methods and timelines. This conference gives you a clear preview of what to expect in the mail.

7. Post-Inspection (Citations and Penalties)

If violations were found, you will receive official citations and proposed penalties by certified mail. You have a few options: you can agree to the citations and pay the fine, you can request an informal conference to negotiate, or you can formally contest the citations. Do not ignore the deadlines!


Frequently Asked Questions About OSHA Inspections

What triggers an OSHA inspection?

There are several triggers, ranked by priority. The highest priority is “imminent danger.” This is followed by any fatality or severe injury, employee complaints, referrals from other agencies, targeted inspections for high-hazard industries, and finally, random follow-up inspections.

Can you refuse an OSHA inspection?

Yes, you can, but it is *highly* discouraged. An employer can deny entry and demand that OSHA get an administrative warrant. However, this is extremely adversarial, and the inspector *will* return with a warrant, often with a much stricter attitude. The best approach is always to be cooperative and professional.

What are the most common OSHA violations?

Year after year, the most common violations are related to Fall Protection in construction. This is typically followed by Hazard Communication (lack of GHS/SDS info), Ladders, Respiratory Protection, and Scaffolding. Checking these areas is a good start for any self-audit.

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