Occupational Safety and Health Administration (OSHA) inspections are not a matter of “if” but when. Simply hearing the words OSHA Inspection is enough to worry or frustrate many safety professionals and managers. Understanding what to expect during an inspection and how to prepare for one can remove uncertainty and negativity surrounding OSHA Inspections. By adopting proactive strategies, companies can mitigate risks, ensure OSHA compliance, and foster a safer workplace environment.
What Are the Different Types of OSHA Inspections?
OSHA can inspect at any time during regular business hours and without advance notice. Therefore, your processes and procedures must be ready to implement in the event of a surprise OSHA inspection. An inspection can happen for a few reasons:
Complaint-based inspections
If an employee files a complaint with OSHA, an inspector will be sent to investigate the issue. The inspection should be focused on the complaint; however, they have the authority to cite any hazard that is in plain sight. When the inspector arrives, ask for a copy of the complaint. If they do not give you a copy, write down the basis of the complaint exactly as they state it. The law prohibits asking for the identity of the complaining employee, so deal only with the subject matter of the complaint. If they request information unrelated to the complaint, don’t hesitate to push back, but remain courteous and professional. Ask them why they want additional information and how it relates to the complaint.
Programmed/Routine Inspections
These inspections focus on specific high-hazard industries or individual workplaces that have experienced high rates of injuries and illnesses. If it is a routine programmed inspection, ask them the basis for the inspection (e.g., forklifts, etc.) and what they want to see related to that basis. Only show them what they want to see and do not provide any additional documentation.
Severe Injury or Fatality
The majority of OSHA Inspections are due to a severe injury, incident or fatality. OSHA requires employees to report any work-related injuries within 8 hours and all work-related inpatient hospitalizations, amputations, or losses of an eye within 24 hours. If the inspection is related to an injury or accident, the questioning should be limited to the specific incident and the employee and witnesses involved. Be prepared to present the employee’s training records and particular elements of the EHS program. They will also want to interview the injured employee and witnesses if they are at work. If not at work, they will go to their home, hospital, or conduct a telephone interview.
Imminent Danger Situations
OSHA has the authority to stop at a work site and intervene immediately if they observe a hazardous condition that presents immediate danger to the health and life of people onsite. The compliance officer will halt work and request that the company correct the hazards immediately.
What Do I Do First When the OSHA Representative Arrives?
The compliance officer will prepare for the inspection before arrival at your site by researching your company’s previous history with OSHA and looking at standards that would most likely apply to your industry. Once the officer is on site, there are three phases to an OSHA Inspection.
The Opening Conference
When the inspector arrives on site, they are required to show their credentials (both a photograph and serial number) to a representative of the company. This action signals the beginning of the inspection. The inspector will then explain why they are conducting the inspection and what they expect to do, including the scope of the inspection, walkaround procedures, documentation required, employee representation, and employee interviews. An employee representative is chosen by the company, not by OSHA. This person plays a crucial role in the investigation. The company representative should accompany the inspector throughout the entire investigation, be respectful and professional, but refrain from providing more information than the inspector requests. They should document all items that the inspector requests and take pictures of everything they document. If you have any trade secrets, remember that OSHA must treat them as such by keeping photos and notes confidential.
Tip: Escort the inspector to a neutral conference room—not your personal office—and notify your safety team immediately.
The Walkaround
Following the opening conference, the inspector and company representatives will conduct a walkthrough of the site, staying within the scope of the inspection. During the walkaround, compliance officers may point out some apparent violations that can be corrected immediately. While the law requires that these hazards must still be cited, prompt correction is a sign of good faith on the part of the employer. Mirror everything they do—take your notes, photos, and measurements for documentation.
Important: The inspector may expand the inspection scope if they see something concerning in plain view. Stay vigilant and try to keep the route direct to the area of concern.
Inspectors may also ask to conduct employee interviews during the inspection process. Employees have the right to participate in private interviews with OSHA inspectors, and any information they share is kept confidential. If an employee feels uneasy, they may decline the interview or request the presence of their direct supervisor, employee representative, or union representative. These interviews provide inspectors with insight into safety procedures, training, use of protective equipment, and overall working conditions from the employee’s perspective. Employers can educate employees on their rights during an inspection.
The Closing Conference
Once the walkaround and interview are completed, the inspector will hold a closing conference with the company representative. During this conference, the inspector will discuss their findings, any potential citations, and possible courses of action for the company (could include informal conferences with OSHA or contesting citations). This meeting provides everyone with an opportunity to clarify any questions and address any misunderstandings.
Discuss possible courses of action an employer may take following an inspection, which could include an informal conference with OSHA or contesting citations and proposed penalties. The compliance officer also discusses consultation services and employee rights. If possible, correct minor hazards before the inspector leaves—this demonstrates good faith and may reduce the severity of citations.
Proactive Approaches to OSHA Inspections
There is no way to prevent an OSHA Inspection entirely, but you can limit your exposure by being adequately prepared in advance.
Create a Culture of Safety & Compliance
Engaging employees at all levels of the organization is a crucial way to enhance safety culture and mitigate the risk of OSHA inspections and citations. Fostering open and transparent communication among all staff levels with clear expectations is paramount.
Conduct Regular Internal Audits
Regular internal safety inspections and thorough job hazard assessments are crucial steps to ensure compliance with safety regulations. Walk your facility like an OSHA inspector would. Internal mock inspections identify issues before they escalate into citations. Periodically review documentation, practices, and employee behavior to ensure compliance.
Educate Employees
Ensure all employees are trained and that their certifications are up to date. Keep digital records accessible and encourage continuous training.
Train your team on what to expect and how to handle inspections, as well as OSHA interviews, professionally. Employees have rights. Let them know:
- They’re not required to speak to OSHA.
- They can refuse recordings and interviews.
- They don’t have to sign statements unless they choose to—and can request translations.
Keep Great Records
Proper documentation serves as proof of compliance while also identifying areas for improvement. Maintain documentation for:
- Training records
- Employee acknowledgments of safety policies
- Complaint resolutions
- Workers’ comp files
- Third-party audits and corrective actions
If it’s not documented, OSHA assumes it didn’t happen.
OSHA inspections can be stressful—but they don’t have to be. With the right systems, mindset, and preparation, they become powerful tools for improving your workplace.
Catamount Consulting provides mining, construction, and general industry businesses with specialized safety services, consultation, and compliance strategies. We have the highest regard for quality and employee safety, and we can help create a safety culture within your organization. Contact us to learn more about preparing for and handling an OSHA Inspection.
