What To Expect During an Oregon OSHA Inspection

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.

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