What Documents will OSHA look at during an inspection?

Getting an OSHA inspection is a rare event.  It would be roughly one in an 400 years if the 30  million businesses get one of OSHA 80000 annual inspections.

Having a complaint, hospitalization or an amputation would be a common inspection that will reduce the odds dramatically. OSHA conducts hundreds of inspections when an amputation or hospitalization has occurred. Complaint inspections are far fewer.

After a work-related hospitalization or an amputation has happened, the employer must call OSHA within 24 hours. 1-800-321-OSHA or osha.gov are ways to submit the information.

OSHA will ask you how the incident occurred and other issues related to the incident.

If OSHA decides to inspect, they will want to look at many documents.

Here is a list for a case where the employee was caught in a nip point of a machiner and broke some fingers.

  • Any and all OSHA-300, OSHA-301 and 300A forms for calendar years 2017, 2018, 2019 and current 2020.
  • Any and all Illinois Form 45 (First Report of Injury) pertaining to the injury sustained by XXXX on April 10, 2020.
  • Any and all documents relating to the XYZ, Inc. written Safety and Health program(s) which was in effect on April 10, 2020.
  • Any and all documentation of training for xxxx before April 10, 2020.
  • Any and all disciplinary rules and or policy(ies), relating to safety and health, in effect on April 10, 2020.
  • Any and all records relating to any safety audits of any job sites performed by the company or on behalf of the company in the past 12 months.
  • Copies of any and all disciplinary action taken against employees of XYZ, Inc. within the previous 12 months.
  • List of XYZ, Inc. employees on the jobsite on April 10, 2020. Please include job title and contact information (phone and address).
  • Any and all documents which relate to the operation of the sheet winder(s), including, but not limited to, any owner’s or operator’s manuals or any instructions or guides provided by the manufacturer of the equipment.
  • Any and all documents which relate to the operation of the sheet winder(s), including, but not limited to, any job safety analysis (JSA) or job hazard analysis (JHA) in effect on April 10, 2020.
  • Any and all recordings or video surveillance from the production department cameras on April 10, 2020, between the hours of 3:30am and 5:30am.
  • Any and all maintenance and/or servicing work orders for guarding devices on the sheet winder(s) from January 1, 2019 to April 10, 2020.
  • Any and all investigation reports prepared by XYZ, Inc. regarding the incident that occurred on April 10, 2020.

Let’s cover the 13 documents.

Document A are the OSHA recordkeeping forms. They can ask for the current year and five past years. The OSHA recording page can help you fill out the forms and download them. They will look to see if similar accidents have happened in the past. Any of the entries that you have on the OSHA log to see if they have been fixed or still pose a hazard.

Document B is the Illinois State worker comp form it is equal to the OSHA 301 form.

Document C is your safety and health program. They may not look at the whole program so try to narrow out which parts they are interested in and give him those sections.

Document D is a training record that you would have for running the machine or lockout.

Document E is your discipline program.  This is the determine whether these issues that caused the accident could be a potential misconduct issue by the employee.

Document F is a copy of all audits that you might have done or the machine or any site inspections for the facility. They want to look at this to see that you are checking to make sure employees are following the safety rules.

Document G is the disciplinary records for employees. They again want to see if there are issues with discipline where the employee might be violating a company rule.

Document H is a list of the employees so they can contact them about the injury or incident and what kind of training and audits they have had in the last few years. I always recommend have these interviews at the company premise and make the employees available. These would be private interviews and you are not allowed as a manager to be in these interviews.

Document I is the machine manual for that piece of equipment that caused the injury. OSHA looks at the manual and the safety precautions as if they were law.

Document J is a job hazard analysis that many companies would do for a machine to identify hazards and the steps to protect a worker during the operation. It is not required by OSHA law but many companies have one already done.

Document K would be the video of the accident and they have a right to see all photographic and video evidence that you might have taken related to the accident.

Document L is any kind of maintenance or service work orders for that piece of equipment there may not be any that relate to equipment causing injury. They would like to see what kind of repairs or requests for work has been outstanding.

Document M is any copies of your investigation which is not usually going to be complete when you get this document request by OSHA. Some companies have a Superintendent incident investigation form or other equivalent documents that must be completed within the 1st 24 hours. So OSHA would want to see what you came up with about the incident.

Knowing which documents OSHA would ask for can help take a lot of the fear out and make sure that you are prepared for an OSHA inspection. OSHA has not even gotten into the required programs such as lockout, personal protective equipment, electrical safety training, fall protection and other programs. Expect other requests to be asked for during the OSHA inspection. I find it most people can follow these 13 items they should be able to handle the initial OSHA request and be in good shape for the inspection.

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