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Regulatory
the inspection in such a manner as to avoid unnecessary CSHO to stop the inspection process because of any type of
personal exposure to hazards. During the walkaround refusal. Never lie to a CSHO; he or she will almost always
inspection it is recommended that the resort gather any find out the truth during employee interviews. If the inspec-
information such as hazard assessments, weekly safety top- tion is stopped, the CSHO will contact his or her area direc-
ics, safety committee topics, standard operating procedures tor, leave your resort, and come back with a warrant and
(SOPs), and specific employee training that is pertinent to other CSHOs to complete the inspection.
the safety of employees in the department being inspected so Please remember that CSHOs are assigned to conduct
the resort can present these materials to the CSHOs at the safety and health inspections through their area office based
closing conference for their review. on high injury and illness DART rates (Days Away from
During the walkaround inspection, CSHOs will bring work, job Restrictions, and/or job Transfers), complaints,
all safety and health violations to the attention of employer referrals, imminent danger situations, fatalities, amputations,
and employee representatives at the time they are recognized and local, regional, and national special emphasis plans.
and documented. The CSHOs will record, at a minimum, They are government employees who will do their best to
the identity of the exposed employee, the hazard to which execute their inspection/mission supported by federal laws,
the employee was exposed, so it is always recommended
the employee’s proximity to build partnerships with
to the hazard, the employ- your resort’s local area office
er’s knowledge of the con- DURING THE WALKAROUND INSPECTION, by cooperating.
dition, the manner in which CSHOS WILL NEED TO CONDUCT During the walkaround
important measurements EMPLOYEE INTERVIEWS OF NON- inspection, CSHOs will need
were obtained, and how long MANAGERIAL EMPLOYEES, WHICH to conduct employee inter-
the condition has existed. IS AN ESSENTIAL COMPONENT OF views of non-managerial
If your resort can immedi- CONDUCTING AN EFFECTIVE INSPECTION, employees, which is an essen-
ately correct any hazards AND VALIDATING AND DOCUMENTING tial component of conduct-
identified during the inspec- POTENTIAL VIOLATION OF HAZARDS ing an effective inspection
tion, every attempt should be IN THE WORKPLACE AND EMPLOYEE and validating and docu-
made to do so. “Corrected menting potential violation
during inspection” (CDI) EXPOSURE TO THOSE HAZARDS. of hazards in the workplace
violations will reflect on-site and employee exposure to
abatement and will be iden- those hazards. Interviews
tified in the citations as CDI provide an opportunity for
at the closing conference. employees to supply valuable facts concerning hazardous
The CSHOs will document interview statements in conditions, including information on how long workplace
a thorough and accurate manner, including names, dates, conditions have existed, the number and extent of employee
times, locations, types of materials, positions of pertinent exposure(s) to a hazardous condition, and the actions of
articles, witnesses, etc. Where entry has been allowed but the management regarding correction of a hazardous condition.
employer interferes with or limits any important aspect of the Interviews are generally documented in writing, and are
inspection, the inspectors will determine whether or not to written in the first person in the language of the individual.
consider this action as a refusal of the walkaround inspection. Employees are encouraged to sign and date their statement.
Other ways CSHOs can consider a refusal by an employer is Any changes or corrections to the statement are initialed by
when the employer won’t allow the examination of records essen- the individual. Statements may not otherwise be changed or
tial to the inspection, the taking of essential photographs and/ altered in any manner. Statements must include the words, “I
or videotapes, the inspection of a particular part of the premises, request that my statement be held confidential to the extent
private employee interviews, and/or the attachment of sampling allowed by law,” and end with the following: “I have read the
devices in order to test sound levels or air quality, for example. above, and it is true to the best of my knowledge.” If the per-
It is always my recommendation for all employers to son making the declaration refuses to sign, the CSHO will
be open, honest, and provide CSHOs with the information note the refusal on the statement. The statement will, nev-
they need to complete the inspection in a timely manner ertheless, be read back to the person in an attempt to obtain
and avoid any unpleasant conversations that could cause the agreement and then noted in the case file.

16 | NSAA JOURNAL | SPRING 2017