An impromptu OSHA inspection is certainly not a joke to most organizations. Fortunately, OSHA provides a way to reduce the possibility of feeling unprepared for such an unnerving occurrence. OSHA offers a free voluntary On-site Consultation Program for small and medium sized businesses to assess their compliance with OSHA, identify workplace hazards, review OSHA standards, and help develop a new or improve an existing injury and illness prevention program.

According to OSHA, a comprehensive consultation includes:

1. An appraisal of all mechanical and environmental hazards and physical work practices.
2. An appraisal of the present injury and illness prevention program or establishment of one.
3. A conference with management on findings.
4. A written report of recommendations and agreements.
5. Training and assistance with implementing recommendations

In 2016, OSHA consultants visited approximately 28,000 small and medium sized businesses responsible for over one million workers. Findings from these consultations are kept strictly confidential and no citations or penalties are assessed during the visit. OSHA stresses the importance of all employee input, maximizing the identification of any potentially unrecognizable hazards in the workplace. To avoid any subsequent OSHA citations and/or penalties, corrective action must be taken in accordance with the employer’s agreement to participate in the On-site Consultation Program. Only in the situation that a hazard is identified as “imminent danger” during the visit must the employer take immediate action to correct the hazard.

There are four steps to completion of the On-site Consultation Program:

• Step 1 Opening Conference to review the employer’s obligations to the program and what the consultant will do throughout the process.
• Step 2 Walk Through of the workplace with the consultant addressing applicable OSHA standards as well as other potential health and safety risks; and identifying hazards with involvement of all employees, if possible.  
• Step 3 Closing Conference includes a written report summarizing the consultant’s findings.  
• Step 4 Abatement and Follow Through as part of the commitment to the program, corrective action must be completed in a timely manner to avoid citations and penalties. Ongoing assistance from the consultant is available during the abatement process as well as staff training and education, if needed.

Following program participation, OSHA does not guarantee an organization will pass a formal OSHA inspection. However, the likelihood of an OSHA inspection may be significantly reduced for those utilizing the On-site Consultation program, particularly for small businesses with 250 or fewer on-site employees and fewer than 500 corporate-wide employees. After completion of the comprehensive consultation, correction of all identified hazards, implementation of an exceptional illness and injury prevention program (for minimum standards see OSHA Safety and Health Management Guidelines: Issuance of Voluntary Guidelines) and demonstration of Days Away, Restricted or Transferred (DART) and Total Recordable Cases (TRC) below the national average, a business may achieve Safety & Health Achievement Recognition Program (SHARP) status. Reaching this goal allows for exemption from a formal OSHA inspection for up to 2 years and subsequent renewal for up to 3 years.
Subscribed clients of First Healthcare Compliance have the benefit of access to the necessary OSHA resources, documents and employee training with a virtual training log to assure ongoing compliance.

For additional OSHA resources, please register for our complimentary May webinars focusing on a variety of OSHA topics.

To apply for a voluntary OSHA On-site Consultation, click here.