For many employers an unexpected visit from OSHA can seem like an uncomfortable prospect.
In this video, we’ll demonstrate an example of what to expect when Oregon OSHA appears
at your workplace for an inspection.
By the end of the video, we hope that you will feel more comfortable from the knowledge
you’ve gained through this example.
When a compliance officer visits your location, they will look for hazards that generally
cause injuries or long-term illnesses.
Since the subject of this program is bloodborne pathogens, we’re going to follow an Oregon
OSHA health compliance officer as he performs an inspection at a clinic.
The compliance officer will always introduce themselves first and provide identification.
They will then inform you that they are there to perform an inspection.
You will need to cooperate with the compliance officer; however, you always have the option
of calling Oregon OSHA to verify the officer’s identity and their authorized presence at
your site.
The next step is to hold an opening conference.
During the opening conference the compliance officer will explain why they are visiting.
They’ll talk about the purpose, the scope, and the nature of the inspection first.
The purpose of the inspection is to assure compliance with OSHA health and safety standards,
and this case includes the Bloodborne Pathogens Standard.
The nature of the visit depends upon how you were selected for a visit.
Priority inspections target activities that could reasonably be expected to cause immediate
serious physical harm or death if continued.
There are also fatality and accident investigations, and inspections based on complaints or referrals.
Programmed inspections work target high-hazard industries meeting selection criteria.
And finally, emphasis inspections focus on the type of industry or a particular hazard
that has been identified by OSHA as experiencing a high level of injury rates.
In this example, we’re looking at a programmed inspection.
Next, there will be a discussion about the types of records that will need to be reviewed.
Records are usually reviewed after the opening conference.
Sometimes the records review takes longer than the inspection allows.
In those situations, the compliance office will have to return.
During a comprehensive inspection a wide variety of documents are viewed, including the OSHA
300 log of injuries and illnesses.
It may also include safety committee minutes and company policies.
The compliance officer will also ask to review your bloodborne pathogens exposure control
plan.
They’ll look for discrepancies in your plan, such as missing information.
For instance, many organizations make the mistake of failing to identify responsible
persons for certain tasks, such as Bloodborne Pathogens training.
Another important aspect is completing the exposure determination, covered in Module
2.
This also gives the compliance officer a better understanding of the culture of an organization
and a direction on how to best assist the employer to improve safety measures.
After finishing the review of documents, the next part of the inspection is the walk-around,
where the compliance officer will look for hazards at your workplace.
There are several areas Oregon OSHA considers when looking for hazards at a health inspection,
such as, work practices, housekeeping, personal protective equipment, and engineering controls.
Compliance officers will take photos, and possibly video, during an inspection.
During the walk around, the compliance officer will also interview some of your employees.
Per the standard, compliance officers will interview a ‘reasonable’ number of employees.
The purpose of the employee interview is to gather as many facts as possible and get a
wide variety of perspectives.
The discussion usually includes questions about any hazards that may have been noticed
in the area that the employee was working in, or general questions about the job.
The compliance officer will also ask questions related to the culture of the organization,
such as how management addresses safety and health concerns.
They will ask other questions to see how well the employees are educated on workplace safety.
After the walk-around the compliance officer will conduct a closing conference.
Sometimes the closing conference has to wait until all records and programs have been reviewed.
However, when it is held, the conference will cover any alleged violations found, the possible
penalties for the violations, penalty reductions you may qualify for, citations that may be
written, and the process for appealing those citations.
The compliance officer will ensure you understand every aspect of the investigation and the
citation process and answer any questions you may have.
They may also give you some resource materials to help you with your next steps or to address
any issues they may have found.
If any hazards are found, they will make sure you know the abatement periods in which you
need to take action.
When a compliance officer completes the on-site inspection, they’ll return to the office
and start their report.
This was a quick example of an inspection.
The process itself can take a bit more time because the compliance officer will be thorough
in their record review, walk through, and employee interviews.
Sometimes this requires return trips.
Oregon OSHA’s goal is to identify hazards and assist employers in creating a safe work
environment.
Next, we’re going to talk about citations and penalties.
Among other topics, we’ll cover the most cited bloodborne-related violations.
Then we’ll have a brief discussion of the impact of an exposure event to your organization,
your employees and the exposed employee.