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THE ARRIVAL OF THE OSHA INSPECTOR joint conference, the CSHO will conduct separate confer-
When CSHOs enter the work site they will come to your ences with the employer and employee representatives.
resort’s main administrative office to present their credentials. The CSHOs will begin the process by informing you
Depending on what is scheduled to be inspected there might of why they are at your resort and what type of inspection
be two CSHOs, a safety CSHO, and a health CSHO. The will be conducted: programmed or unprogrammed. A “pro-
CSHOs will then request to see the highest management grammed” inspection is a worksite safety and health inspec-
official onsite to begin the “opening conference” (described in tion that has been scheduled based upon objective or neutral
the next section). selection criteria. The worksites are selected according to
CSHOs will always present their credentials and busi- national scheduling plans, or under local, regional, and
ness cards whenever making contact with management rep- national special emphasis programs. An “unprogrammed”
resentatives, employees (to conduct interviews), or organized inspection is scheduled in response to alleged hazardous
labor representatives. I recommend that while they are wait- working conditions identified at a specific worksite. This
ing for management staff (chief executive officer, chief oper- type of inspection responds to imminent dangers, fatalities/
ating officer, human resources director, and/or risk manager) catastrophes, complaints, and/or referrals.
to arrive, you bring them to a conference room or other quiet The inspectors will also clarify the scope of the inspection,
area and give them a copy of your resort’s orientation manual, either comprehensive or partial. CSHOs will outline in gen-
safety and health manual— eral the terms of the inspection,
along with the last five years including the need for private
of your resort’s OSHA employee interviews, physical
300 logs, which detail all inspection of the workplace and
work-related injuries and records, possible referrals, your
illnesses—so they can COMPLIANCE OFFICERS RARELY GIVE rights during an inspection, dis-
review the material while NOTICE OF THEIR VISIT. THEY ARE crimination complaints, and the
they wait. CSHOs will REQUIRED TO FOLLOW SECTION 17(F) closing conference process.
request the OSHA 300 logs OF THE OSH ACT, WHICH PROHIBITS They will inform partic-
during the opening confer- GIVING ADVANCE NOTICE OF ipants that a camera, video
ence, so by giving them this INSPECTIONS, EXCEPT AS AUTHORIZED camera, and/or an audio
information upfront you BY THE OSHA SECRETARY. recorder may be used to pro-
are helping establish trust vide a visual and/or audio
as well as showcasing that record, and that the photos,
your resort is proactive with videotape, and audiotape may
employee safety and health be used in the same manner as
programs and regulatory handwritten notes and photo-
requirements. graphs in OSHA inspections.
The inspection shall not be delayed unreasonably to CSHOs also will explain to employers the advantages of
await the arrival of the employer representatives. If the immediate abatement, including that there are no certifica-
employer representative is coming from off-site, the inspec- tion requirements for violations quickly corrected during the
tion should not be delayed more than one hour. inspection. The inspectors will advise both the employer and
employee representatives, if applicable, that the “quick-fix
OPENING CONFERENCE penalty reduction” may be applied to each qualified violation
CSHOs review the conditions of the worksite upon arrival as that the employer immediately abates during the inspec-
well as any changes that may occur during the opening con- tion and that is visually verified by the CSHOs. As soon as
ference. At the start of the opening conference, CSHOs will the opening conference is completed, the compliance officers
inform both the employer and the employee representative(s) will begin the walkaround portion of the inspection.
of their rights during the inspection, including the opportu-
nity to participate in the physical inspection of the workplace. WALKAROUND INSPECTION
CSHOs will conduct a joint opening conference with The main purpose of the walkaround inspection is to iden-
the employer and employee representatives, including tify potential safety and/or health hazards to which employ-
unions, unless either party objects. If there is objection to a ees are exposed in the workplace. The CSHOs will conduct
SPRING 2017 | NSAA JOURNAL | 15

