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United States Department of Agriculture

Agricultural Research Service

Surviving an OSHA Inspection
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SURVIVING AN OSHA INSPECTION

(With the caveat that state and other inspections are different)

Major Regulatory Interest: Unless they’re investigating a fatality, complaint, or other major issue, most regulators are primarily interested in five things:

Records The inspector’s first stop. They’re interested in your Agency OSHA poster (usually called the OSHA 2203, actually the AD-1010), the annual accident log (in Federal workplaces often mistakenly called by its industry name, the "OSHA 200 Log"), and other records that back up your programs: training meeting records, safety committee minutes, records of safety inspections (and fixes!), financial expenditures, etc.

If your records are conveniently found (demonstrating to the inspector that you refer to them frequently enough to know immediately where they’re kept), if they’re in some semblance of order, and if they appear to be genuine (i.e., the names on the safety meeting sign-in sheets should not be in the same color ink, and handwriting), you’ve established the atmosphere for a fairly light handed inspection.

Written Programs They will want to see documentation on the major programs. ARS Manual 230 gives general guidance on most everything you’ll need, but the inspector will expect location-specific programs for: Hazard Communication and Community Right-to-Know, facilities self protection and emergency planning, personal protective equipment (including respiratory), lockout/tagout, chemical hygiene, bloodborne pathogens (if applicable), hearing conservation, training, and confined space entry.

        Management They will want to see responsibilities of management and staff, including

Accountability Signs that your management supports the programs. These are outlined in ARS Manual 230, and can be customized for your location programs.

Employee Awareness Although the inspector may ask employees what they know about your safety program, two things will help demonstrate good awareness:

1. Records of training, with a list of attendees and a test. Many regs require regulation-specific training

2. A good signage program around the lab - hazards well marked and identified, safety tips, safety posters, appropriate signs (e.g., NRC, biohazard, etc.) for your special hazards.

Obvious Hazards Most inspectors are generalists. Unless your inspector has specialized technical knowledge, or unless you have some especially eye catching operation, most inspectors will concentrate on obvious, easily remedied hazards.

 

PROGRAM

MANUAL 230

YOUR 1ST

CONTACT

COMMENTS

Accident Statistics

A-IV.H

APS, ASHM

 

 

Asbestos Abatement

C-III

AOE, ASHM

 

 

Biological Safety **

D-IV.T

Bio, ASHM

Mike Kiley on the National Program Staff oversees program. Oriented toward lab design & practices.

Bloodborne Pathogens**

(AIDS, Hepatitis B, etc.)

 

 

ASHM, Bio

ASHMs tend to take the lead on this, in consultation with Mike Kiley

CERCLA

D-IV.M

ASHM

Comprehensive Environmental Response, Compensation, and Liability Act - Cleanup of contaminated sites

Chemical Hygiene*

C-VIII

ASHM

Object: Protect employees from chem exposures

Clean Water Act

D-IV

ASHM

 

 

Community Right-to-Know*

D-IV

ASHM

Object: Notify communities and emergency responders of our chemical hazards

Confined Space Entry**

C-VII

ASHM

 

 

Design/Construct

Man 242.1

AOE

Build safety into your lab from ground up

EAP

B-II

APS

Employee Assistance Program - Psychological help

Emergency planning

 

 

ASHM, CEPS

 

 

Enviro Management

D

CEPS, ASHM

 

 

Facilities self protection*

 

 

P&P

Most facilities use GSA generic FSP plan

Fuel Storage Tanks*

D-IV

ASHM, CEPS, AOE

We must fix or replace leakers, and install appropriate spill and leak equipment on all

Fume Hood/Ventilation

D-IV

ASHM

Helpful inspection information also contained in old (and outdated) ARS Manual 232.1

Hazard Communication*

C-IV

ASHM, CEPS

Object: Advise employees of chemicals and other hazards at their worksite

Hazwaste Management*

D-IV.H, ff.

ASHM, CEPS

Chemical disposal, primarily

HazWaste Cleanup, HWC

D-II.E

ASHM/CEPS, SHEMB

HWC provides $ for cleanup of past environmental sins, with out-of-agency funds.

Hearing Conservation

C-VI

ASHM

Whatdja say?

Industrial Safety

 

 

ASHM

You name it, the ASHM does it

Industrial Hygiene

C

ASHM, CEPS

 

 

Inspection/Abatement

A-VI

ASHM, CEPS

A revised ARS 404 self inspection form is in next-to-final draft

Laboratory Safety

D-IV.R, ff.

ASHM, CEPS

 

 

Life Safety Codes

 

 

AOE, ASHM

From the Natl Fire Protection Assn fire codes

Lockout/tagout**

C-VII

ASHM

Object: Control energy during maintenance

Manual 230.0

Duh...

ASHM, CEPS

Revised & updated manual soon to be issued

National Environmental Policy Act

C-II.C

AOE, ASHM, CEPS

NEPA - environmental assessments for construction & major research

Occupational Health Maintenance Program

B

ASHM, APS

The OHMP matrix from 1983's Manual 235.1 is still in effect...and not reproduced in Manual 230.0!

OWCP

A-IV.H

APS

Workers’ Compensation

Personal protective equipment*

A-V.E

ASHM, CEPS

You must perform written risk assessments to determine the type of PPE your people need

Pesticide Management

D-III.J

ASHM, CEPS

Manual 230 not yet updated to include Pesticide Worker Protection Standard

Radiation Safety

D-IV.V

RSS

In some Areas, the ASHM/CEPS assist, but in all cases, RSS has primary jurisdiction

RCRA

D-IV

CEPS, ASHM

Resource Conservation and Recovery Act - hazardous and chemical waste management

Safety Committee

A-IV.C

ASHM

Can also include many other functions - chemical hygiene, biosafety, radsafety, etc.

Training

A-III

ASHM

Training, in some form or fashion, and in some cases quite rigorous, is required for almost all the above programs.

NOTE: This list is not all inclusive. Also, Manual 230 is being updated and is in its next-to-final format. The above citations are for the current Manual and will not be the same in the new manual.


Last Modified: 4/26/2005
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