Are Third Party Safety Inspections The Best Course of Action for My Facility?

The Occupational Safety and Health Administration (OSHA) maintains a full-time staff of inspection officers, called compliance safety and health officers (CSHO). OSHA has jurisdiction over most worksites and can enforce the rules and regulations pertaining to the specific industry of the worksite. These rules and regulations can be found in your industry’s specific standards. For general industry, these standards are 29 CFR 1910 (General Industry Standards). For construction, these standards are 29 CFR 1926 (Construction Industry Standards).

An OSHA inspection can be conducted either on-site or by phone/fax. During an on-site inspection, the CSHO may walk through portions of the worksite, will review worksite injury and illness records, and will observe the posting of the official OSHA poster. The inspector is also very likely to interview employees privately, without management present, to discuss site safety.

These inspections can occur for several reasons. Inspections are prioritized for worksites in the following order of priority:

  1. Imminent danger situations. These are for hazards that could cause death or serious physical harm.
  2. Severe injuries and illnesses. These are related to any work-related fatalities, hospitalizations, amputations, or losses of an eye.
  3. Worker complaints. These are for allegations of hazards or violations by workers.
  4. Referrals. These are related to referrals by other federal, state, or local agencies, individuals, organizations, or the media.
  5. Targeted inspections. These are for high-hazard industries or individual worksites that have experienced a high rate or injury or illness.
  6. Follow-up inspections. These are for checks of abatement of violations cited during previous inspections.

After an inspection has occurred, the CSHO will create a list of any citations or fines based on observations from the site visit. The findings are reviewed by the Area Director, who decides the level of violation and associated citation penalties. From this, a facility will have to implement any corrective actions noted from this inspection, as well as pay any related fines. Otherwise the facility can send a representative for an Informal Conference with the Area Director to dispute the findings, or show the steps taken towards hazard abatement and mitigation in order to lessen the financial penalties. Alternatively, a facility can fight the findings in court.

Because facilities can face severe penalties and fines from violations found during an OSHA inspection, all facilities should be routinely conducting safety audits to identify potential safety and health violations. All facilities should consider conducting these safety audits, documenting any results, and routinely implementing corrective actions. In fact, OSHA has a final policy describing the treatment of audits that assess worksite safety and health conditions will not be routinely requested and will not be used as a means of identifying hazards upon which to focus. In addition, where a voluntary audit identifies a hazardous condition and the employer has corrected the violation prior to the inspection and has taken steps to prevent the recurrence of the condition, OSHA may likely refrain from issuing a citation. When an audit identifies a hazardous condition, and the employer promptly takes appropriate measures to correct the violative condition and to provide interim employee protection but has not completely corrected the condition when the inspection occurs, OSHA will treat the audit, and steps taken towards hazard abatement and mitigation, as evidence of good faith and not as evidence of a willful violation of OSHA rules and regulations. To see more information about this rule, see the following link: https://www.osha.gov/laws-regs/federalregister/2000-07-28

When performing safety and health audits, facilities have two choices: Conduct the audit internally or have a third party come in to perform an audit. So, why should you have these inspections be conducted by a third party?

First, third party inspections are unbiased in their analysis. A third-party inspection is looking for all potential issues that may arise during an OSHA inspection. This can include document reviews of records, programs, and trainings or physical assessments for things such as machine guarding, electrical issues, or blocked egress routes. Companies that are hired to conduct inspections should be on your side, aiming to help your facility prevent any potential OSHA violations, and even more importantly, help your facility prevent any potential employee illnesses or injuries. Additionally, third-party inspectors may be more familiar with OSHA rules and regulations and can bring extra experience to the inspection, as well as the areas of interpretation and best management practices related to that hazard or regulation.

Another reason facilities should consider hiring a third party to conduct their safety audits is to avoid inattentional blindness. Inattentional Blindness is a phenomenon that occurs when people focus on things that are most important to them. The following video acts as a quick demonstration of how easy it can be to fall victim to inattentional blindness. https://www.youtube.com/watch?v=vJG698U2Mvo

As employees of a business, it can be easy to focus on your daily tasks, and to get in a routine where you only notice things that are out of the ordinary. Even someone who’s role is dedicated to safety can potentially overlook hazardous conditions if they have grown accustomed to them. Third party inspections can help alleviate this issue. Since a third-party inspector is not familiar with your facility or the exact nature of your process, any potential issues will typically be easier to notice and document. Having a third-party inspector visit the facility can also help simulate a real OSHA inspection as the inspector may be more thorough and see the facility through a different lens.

Services CTI offers.
CTI offers services that range from full site safety audits to one-off programs. We have an extensive background in safety regulations and requirements as well as a deep understanding of manufacturing processes. See our OSHA Compliance page on our website for an example list of services we can provide. https://www.conversiontechnology.com/osha-compliance-consulting/ All of CTI’s findings and inspection reports are kept confidential and are for internal use by CTI and your facility only. Please feel free to reach out to us today so we can tailor our services to your facility’s specific needs.

OSHA Compliance Consullting Services

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