You’re having one of your most hectic days when someone who’s not on the schedule walks in. Rather than presenting an insurance card, you are presented with a government identification badge. Your office is about to undergo an unannounced OSHA inspection!
What could you expect if OSHA showed up at your front desk? Here are five key components of an OSHA inspection that will help you be prepared if an inspector showed up at your door:
1. Opening conference. During the opening conference the inspector will meet with representatives of management (e.g. doctor and/or Office Manager) and employees to explain the purpose of the inspection. The inspector will present a list of documents to be examined.
2. Review of documents. Typically, the inspector will want to see your bloodborne hazard assessment, OSHA/safety policies and procedures, training records and employee medical files. You may be asked to produce other documents as well.
3. Walk-around. Sometime during the visit, the inspector, accompanied by management and an employee representative, will take a tour of your office. The inspector will be checking employee safety, such as whether you provide the proper personal protective equipment for the tasks performed, whether you use safety-engineered devices to prevent needlestick injuries, how chemicals are handled, and whether the eye wash station is working properly.
4. Individual interviews. The inspector will meet individually with some of your staff to discuss any safety concerns. This interview is confidential; you are not permitted to question the employees about the interview or retaliate because you think they complained to OSHA.
5. The closing conference. At this time, the inspector will review any “apparent violations” and suggest ways to correct hazards so you can avoid deadlines and possible fines. Correcting violations while the inspector is there will lessen potential fines. The inspector will let you know if no concerns or violations were found.
OSHA must issue any citations within six months of the inspection. If you don’t hear anything, no news is good news! However, once you receive formal notice of violations and corresponding fines, you have only 15 days to contest in writing or pay the fine.
Having a strong compliance program is foundational to running a profitable and legally sound practice. We advocate prevention to our patients, so why not apply that same approach to OSHA compliance?