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For a description of the various OSHA inspections, visit CSHOs will outline in general terms the scope of the
www.osha.gov. inspection, including the need for private employee inter-
views, physical inspection of the workplace and records, pos-
INSPECTION PROCEDURES & SCOPE sible referrals, that video and audio recording will occur,
The inspection itself may take a few hours or several weeks rights during an inspection, discrimination complaints, and
depending on the type of inspection being conducted, the the closing conference(s) process. The opening conference is
size of the company, and the number of hazards identified usually brief so that the compliance officer may quickly pro-
that employees are exposed to during the walkaround. The ceed to the walkaround.
scope of the inspection may be either comprehensive or par- In some cases, employers can provide immediate abate-
tial. In rare instances, the employer may have the right to ment of issues. CSHOs generally explain to employers the
refuse the inspection. Regardless, an employee representative advantages of immediate abatement, including that there
is always allowed to be present during the inspection. are no certification requirements for violations quickly cor-
rected during the inspection. In some cases, this may
COMPREHENSIVE INSPECTION: A substantially complete and result in penalty reductions. If a CSHO requests injury
thorough inspection of all potentially hazardous areas of the and illness records, an employer must provide copies of the
establishment, even though, as a result of professional judg- required recordkeeping records within four business hours.
ment, not all potentially hazardous conditions or practices Remember, though, the compliance officer is not required
within those areas are inspected. to wait until the records are provided before beginning the
walkaround portion of the inspection; he or she can start as
PARTIAL INSPECTION: May be limited to certain potentially soon as the opening conference is completed.
hazardous areas, operations, conditions, or practices at the An abbreviated opening conference will be conducted
establishment. Partial inspections can be expanded based on whenever the CSHO believes that circumstances at the
information gathered during the records or program review worksite dictate that the walkaround begins as promptly as
and walkaround inspection, to determine whether expand- possible. In these cases, the opening conference will con-
ing the scope of an inspection is warranted. sist of presenting credentials, stating the purpose of the visit,
explaining employer and employee rights, and requesting
REFUSAL OF INSPECTION: CSHOs may enter without delay employer and employee representatives. Everything else will
and at reasonable times any establishment covered under the be addressed fully during the closing conference(s).
Act for the purpose of conducting an inspection. Unless the At the start of each inspection, the CSHO will review the
circumstances constitute a recognized exception to the war- employer’s injury and illness records for five prior calendar
rant requirement (e.g., consent, third party consent, plain
view, open field, open construction site or exigent circum-
stances), an employer has a right to require that the CSHO A starting point to workplace safety in
seek an inspection warrant prior to entering an establishment your resort is first to identify what
and may refuse entry without such a warrant. hazards OSHA has cited this past year.
Following are the top 10 violations for
EMPLOYEE PARTICIPATION: Section 8(e) of the Act and General Industry in 2016:
§1903.8 requires that an employee representative be given an • Fall protection
opportunity to participate in the inspection. • Hazard communication
• Scaffolds
OPENING CONFERENCE • Respiratory protection
During the opening conference, CSHOs will try to inform • Lockout/tagout
all affected employers of the purpose of the inspection, pro- • Powered industrial trucks
vide a copy of the complaint if applicable, and include any • Ladders
employee representatives, unless the employer objects. Unless • Machine guarding
the employer or employee representative objects, this will be • Electrical wiring
a joint opening conference. If there is an objection to a joint • Electrical, general requirements
conference, the CSHO will conduct separate conferences
with employer and employee representatives.

WINTER 2017 | NSAA JOURNAL | 17