“Care, Protect, Grow”: The U.S. Compliance Blog

Introduction

Every year, OSHA publishes a list of the Top 10 Most Cited Violations from the fiscal year across general industry and construction standards. Even with increased attention to health and safety in the workplace, the Top 10 has many constants year after year. Complex standards lead to a direct relationship between the Top 10 Most Cited and the top 10 highest penalties from the year (ranging from $530,592 to $1.792 Million in FY 2019). As was the case in 2018, the 2019 list was split down the middle with five standards for construction and five standards for general industry. Whether you are a large scale operation or a small business, these standards may apply to you.

1. In the number one spot with 7,014 violations, is the construction industry standard for Fall Protection (1926.501) – the corresponding general industry standard would be 1910.28. Though the citations fall primarily within the construction industry, the general industry standard could also be cited at your facility. Employers are responsible for the following:
   • Assessing their facilities to ensure employees are not exposed to unprotected open-sided floors, leading edges, floor holes or runways
   • Evaluating facility tasks to ensure employees are not exposed to a risk of falling when performing service at an elevation
   • Protecting employees from the risk of falling from surfaces above 48 inches (4 feet) in height through the use of approved guard rails where feasible
   • Incorporating the use of personal fall arrest systems when working at elevated heights outside of an approved railing or guard rail system
   • Training employees on the proper use and care of the personal fall arrest systems used at your facility
   • Inspecting all personal fall arrest systems prior to each use

2. Second on the list – but first on the minds of many of our general industry partners and clients – is Hazard Communication (1910.1200). One of the older standards, Hazard Communication or HazCom/GHS/Right-to-Know/WHMIS (Canada), is how we communicate chemical and non-chemical hazards to our employees and visitors. As we think about Hazard Communication, we can envision a wagon wheel with spokes touching many other standards, including Personal Protective Equipment and Respiratory Protection. It is easy to see how important hazard communication can be. As a general industry employer, it is the employer’s job to:

1. • Inform and train their employees on the hazardous chemicals in their area (1,087 violations)
   • Have a site-specific written program (1,521 violations)
   • Establish a labeling system (352 violations)
   • Ensure that safety data sheets (SDS, formerly MSDS) are accessible (740 violations)

3. Closely related to the #1 most cited standard, the construction standard that is third on the list is Scaffolding with 2,813 violations. The general industry standard that is most closely related to the Scaffolding standard is the Walking-Working Surfaces Standard. Standard 1910.22 requires that the employer:

1. • Ensure all places of employment are kept clean, orderly and in a sanitary condition
   • Ensure that walking-working surfaces are maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spill, snow, and ice
   • Ensure that walking-working surfaces can support the maximum intended load for that surface
   • Ensure that each means of access and egress to and from all walking-working surfaces are safe
   • Ensure that walking-working surfaces are inspected regularly and as necessary to maintain a safe condition
   • Ensure that hazardous conditions are corrected or repaired before an employee uses the walking-working surface again
   • Ensure that when any correction or repair involves the structural integrity of the walking-working surface, a qualified person performs or supervises the correction or repair

4. Number four on the OSHA Top 10 of FY 2019 was Lockout/Tagout (1910.147), also known as the Control of Hazardous Energy. As one of the standards with the highest applicability across all of our clients, this standard had 2,606 violations. As an employer, you must do the following:

1. • Formalize a Lockout/Tagout (LOTO) program for use when maintaining, cleaning, or adjusting machinery where unexpected equipment activation could cause injury (300 violations)
   • Develop machine-specific procedures (1,063 violations)
   • Complete periodic inspections of authorized employees (500 violations)
   • Provide initial and periodic training to their employees (572 violations)

5. Dropping one spot from the FY 2017 and FY 2018 list is the Respiratory Protection standard (1910.134). With 2,450 companies failing to meet the requirements of this standard, it is a consistent pillar of the OSHA Top 10. With citations including failure to establish a program, failure to perform fit testing and medical evaluations, this standard requires you to complete the following:

1. • Quantify the chemical concentration level to which employees are exposed
   • Implement engineering or administrative controls where air contaminant levels exceed required thresholds
   • Develop, implement and maintain a Respiratory Protection program where respirators are used (449 violations)
   • Provide annual training and fit testing (446 violations)
   • Provide a medical evaluation to determine an employee’s ability to use a respirator (518 violations)

6. At 2,345 violations, Ladders take the 6th spot on the list of the Top 10 Most Cited Violations. While the specific standard reference is the construction standard, Ladders in general industry (1910.23), it is also included in the fall protection standard. Standard 1910.23 requires that employers in general industry:

1. • Provide ladders and step stools that have uniformly spaced rungs, steps, and cleats that are parallel, level and uniformly spaced
   • Ensure ladders are inspected before initial use in each work shift and more frequently as necessary to identify any visible defects that could cause employee injury
   • Ensure any ladder with structural or other defects is immediately tagged “Dangerous: Do Not Use” or with similar language in accordance with 1910.145

7. At number seven on the list, there were 2,093 companies in general industry that did not follow the standard requirements that govern one of the biggest pieces of equipment in their facility in both size and quantity – Powered Industrial Trucks (or forklifts). Standard 29 CFR 1910.178 requires that the employer completes the following:

1. • Ensure that each operator has successfully completed operator training before operating a powered industrial truck on the job (592 violations)
   • Conduct pre-use inspections prior to every shift (357 violations)
   • Practice safe operations in accordance with 1910.178(l)(1)

8. Not to be confused with the standards in the first, third, or sixth spot, the construction industry standard for Fall Protection (1926.503) comes in at number eight with 1,773 violations. Having moved up two spots from the 2017 and 2018 ranking, this portion of the fall protection standard from construction focuses specifically on the training requirements. One of the biggest groups out of the 1,773 violations was the failure to certify training in writing. Always remember – if it didn’t get documented, it didn’t happen.

9. The last general industry standard within the Top 10 is OSHA’s Machine Guarding Standard (1910.212) with a total of 1,743 violations. Often tied in closely with its cousin in the number four spot, the machine guarding standard requires that employers:

1. • Affix guards and secure them to machines that do not introduce a new hazard (1,880 violations)
   • Anchor fixed machinery to prevent walking or moving during operation (101 violations)

10. Finally, rounding off the Top 10 is Personal Protective and Lifesaving Equipment for the construction side with a focus on eye and face protection. At 1,411 violations and in the same position as last year, employers were commonly cited for failure to provide eye protection with side protection and failure to provide protection from causative hazards, such as gases and vapors. A common misconception within general industry when dealing with tasks like grinding and working with chemicals like battery acid is the idea that once an employee has safety glasses on, they are fully protected. That couldn’t be further from the truth. PPE only works if you’re wearing it and wearing the correct type. Safety glasses by themselves do not prevent acid splash or flying projectiles from hitting an employee’s mouth, forehead or ear.

Conclusion

The OSHA Top 10 list is a helpful guide for understanding just how adept businesses are in complying with the basic rules of workplace safety. By being able to take these items and apply them to your facilities, you can move your company in the right direction towards compliance and safety.   Some starting points to consider are to take these topics and ensure that you have developed site-specific programs. You will also want to complete authorized and awareness level training, making sure to document it and begin implementing these changes on your plant floor. We also recommend reviewing your programs on a regular basis; due to the ever-changing environment of a manufacturing facility, you need to make sure our safety programs are current and accurate. If you haven’t already, make sure to check out our blog on OSHA Inspection protocols and ensure your employees know what to do when OSHA comes knocking!

Employers with 10 or more employees are required to prepare and maintain regular records of serious occupational injuries and illnesses using the OSHA 300 Logs unless they are deemed a low-risk exemption by OSHA.

This information helps employers, workers, and OSHA in evaluating the safety of a workplace, understanding its possible hazards, and implementing worker protections to reduce and eliminate hazards. It is important to always maintain accurate injury logs as the requirements are enforceable under OSHA Recordkeeping regulation 29 CFR 1904. This article will help detail the information required on each log and give tips on how to ensure timely and accurate reporting.

Recordkeeping Requirements

All work-related injuries that result in death, loss of consciousness, restricted activity, lost days from work, or any other treatment beyond first aid must be logged and accounted for on a variety of logs. These are called Recordable Injuries. The forms used to complete this documentation are the 300A, 300, and 301 Logs. All of the logs can be found on OSHA’s website.

OSHA Recordkeeping: First Steps

If a workplace injury was to occur, it is necessary to classify the case correctly and determine if the incident needs to be documented on the appropriate logs. Within seven days of the first report of a workplace injury, the following steps must be taken:

1. Determine if the incident meets the criteria to be an OSHA Recordable Injury, as described above.
2. Determine whether this is a new case or the recurrence of an existing injury from a prior incident. Only new cases should be recorded.
3. Establish and ensure the case was work-related.
4. Select and complete an Injury and Illness Report Form. This must be the OSHA 301 Form or an equivalent that includes, at a minimum, all the information found on the OSHA 301.

OSHA Forms and Logs

Form 301

The OSHA 301 Form should be the first piece of documentation completed following a recordable workplace injury. This form is used to investigate the incident and document the events that lead to the injury occurring. The 301 Form contains 18 questions that assist with determining what lead to the injury. Employers are required to complete and retain a 301 Form for each recordable workplace injury. An employer may use their own incident investigation paperwork, but it must include all of the information on OSHA’s 301 Form.

While it is not required to submit these forms to OSHA, it is required per OSHA recordkeeping regulations that one is completed and retained for five years following all recordable injuries.

300 Log

The OSHA 300 Log is a summary log of each workplace injury that meets the OSHA recordkeeping criteria. It includes information from the 301 Form and condenses it into a line item in a list format. When completed, it allows for easy comparison of all the recordable injuries that occurred during the calendar year. An entry on the 300 Log should be completed within seven days of an OSHA recordable injury. When working with the log, the following steps should be taken:

1. Identify the employee involved unless employee privacy is a concern.
2. Describe when and where the incident occurred.
3. Describe the case with as much detail as possible using available information.
4. Classify the case based on the seriousness of the outcome by selecting one of the following:

• • • • • Death (column G)
        • Days Away (column H)
        • Job Transfer/Restriction (column I)
        • Other recordable cases (column J)

1. Track the number of days an employee is either:
   1. Away from work (Days Away)
   2. Working under restriction or job transfer (Restriction/Transfer)
2. Record whether the incident is an injury or an illness. If the case is an illness, select the appropriate illness on the form.

Tracking days on the 300 Log:

Determining exactly how many days to track on a 300 Log entry may seem confusing; the below points will help you successfully count Days Away or Restricted/Transfer time:

1. Count the number of calendar days starting the day AFTER the incident. In other words, do not count the day of the injury/illness.
2. If the incident results in both Days Away and Restricted/Transfer, both will need to be tracked.
3. The maximum days counted is 180. This includes the combination of both Days Away and Restricted/Transfer or either independently.
4. Only track the incident on the calendar year form in which it occurred. For example, if an incident occurs in 2019 and the days tracked continues into 2020, do not create a new item on the 2020 Log. Instead, include an estimate on the initial year’s 300 Log and then update it once the employee returns to full duty or the 180-day limit is reached, depending on which occurs first.

300A Log

The 300A Log is a summary of the information found on the 300 Log. To complete the 300A Log, you must use the information provided directly from your 300 Log.

The final piece of information needed to complete this form is the total number of hours worked at the facility and the average number of total employees. This information is used in conjunction with incident data to determine a worksite’s incident rate. You can obtain this information from payroll.

Note: Even if no recordable incidents occur during a calendar year, you will still be required to complete a 300A Log. Enter a “0” in all of the categories and input the Hours Worked information. The highest-ranking employee at the facility or another company executive must sign the 300A Log to complete.

Submission, Retention and Posting Logs

All OSHA Logs must be maintained for a minimum of five years. The 300A Form is the only log with a specific posting or submission requirement. Once completed, the 300A Form must be posted in a conspicuous location of the facility for employee review from February 1 to April 30 of each year. This could include a bulletin board, communication board, TV, or another highly visible area. Employers may be required to submit their 300A Log online annually based on their number of employees and industry. The criteria for this requirement can be found on OSHA’s Injury Tracking Application found here.

Additional Resources

https://www.osha.gov/recordkeeping/

https://www.osha.gov/injuryreporting/index.html

https://www.osha.gov/report.html

https://www.osha.gov/injuryreporting/index.html

On November 20, 2019, the U.S. Environmental Protection Agency (EPA) signed the Risk Management Program (RMP) Reconsideration Rule as a result of three petitions submitted to reconsider the RMP regulations mandated in 2017. According to the EPA, this new rule rescinds and modifies certain revisions in order to “better address potential security risks, reduce unnecessary and ineffective regulatory burdens on facilities and emergency responders, harmonize rather than conflict with the Occupational Safety and Health Administration’s (OSHA) Process Safety Management standard, address the concerns of stakeholders,” and save unnecessary costs for facilities and regulatory departments.

The following provisions have been modified under the EPA’s RMP Reconsideration Rule and may impact regulated facilities:

• Retains the requirement that facilities must annually coordinate with local response organizations in order to reduce the impacts of a potential incident.

Compliance Date: March 14, 2018

• Modifies emergency coordination provisions to address security concerns with the 2017 amendment. Emergency response planners may now only obtain information that is necessary to complete and implement local emergency response plans.

Compliance Date: N/A

• Retains annual emergency notification drill provisions.

Compliance Date: First notification must be performed five years after date of publication

• Retains the requirement to perform tabletop exercises with facility personnel and local responding agencies to discuss emergency response practices in the event of an incident.

Compliance Date: First tabletop exercise is due seven years after date of publication

• Modifies the frequency of field exercises as well as the scope of the documentation required for the field exercise and evaluation report to provide more flexibility to local emergency responders.

Compliance Date: Date is determined by owner/operator of facility and local emergency response agencies

• Retains the requirement to hold a public meeting within 90 days after an accident, but only applies the requirement to accidents with offsite impacts.

Compliance Date: Following any RMP reportable accident with offsite impacts that occurs after March 15, 2021

The following provisions have been rescinded under the EPA’s RMP Reconsideration Rule unless specifically required by the EPA:

• Third party audits are no longer required
• The need to conduct a Safer Technologies and Alternatives Analysis (STAA) has been rescinded to avoid unnecessary costs and potential overlap of the safer technologies implemented within the Process Hazard Analysis (PHA)
• Conducting an Incident Investigation Root Cause Analysis after a reportable incident or near miss is no longer required in order to maintain consistency with OSHA PSM standards
• The availability of facility RMP information will no longer be made available to the public due to security/terrorism threats. However, State and Federal regulators and first responders will have no information restrictions under this new rule. The public can access RMP information through read-only access at Local Emergency Planning Committees (LEPCs), Federal Reading Rooms or through a Freedom of Information Act (FOIA) request to the EPA.

Ultimately, this new rule reduces regulatory requirements and security risks for facilities applicable to RMP Regulations

Under the Clean Water Act, the EPA put the Metal Finishing Categorical Pretreatment Standards into effect on July 15, 1983, as 40 CFR Part 433. The regulations cover wastewater discharges from a wide variety of industries performing various metal finishing operations. More specifically, the metal finishing operations applicable to the standard mostly involve the process of changing the surface of a metal object to improve its appearance and/or durability. Applicability of the Metal Finishing Category is defined by the type of process operation versus the industry sector.

The primary goal of the standard is to prevent the uncontrolled discharges of wastewater pollutants from industrial facilities with metal finishing operations. To accomplish this, limitations on the pollutants are implemented within the standards. These limits also prevent the discharge of pollutants that could pass through, interfere with, or otherwise be incompatible with the local wastewater treatment plant that receives the wastewaters.

DOES YOUR FACILITY HAVE METAL FINISHING OPERATIONS APPLICABLE TO 40 CFR 433?

The Metal Finishing Standard regulates wastewaters generated from six primary metal finishing operations. The primary six operations are outlined below.

If a facility conducts any one of the six operations listed above, a Categorical Wastewater Permit is required. This applies even if the wastewaters generated from the process are sent out for disposal as a hazardous or non-hazardous waste (versus discharging to the sanitary sewer). Often termed zero discharge, a facility with no discharge to wastewater can still need a permit if they meet the categorical requirement.

ADDITIONAL PROCESS WASTEWATERS REGULATED

If a facility conducts one of the primary metal finishing operations and is applicable for permitting, then the standard also covers additional wastewaters resulting from an additional 40 metal finishing operations (that may or may not be present at the site). To comply with the metal finishing standard, it is the facility’s responsibility to identify the additional metal finishing wastewaters during the permitting process. The additional 40 operations are outlined below.

Source:  https://www.epa.gov/sites/production/files/2018-05/documents/metal-finishing_prelim-review_april-2018.pdf

PRIMARY REQUIREMENTS

Once a facility has determined that a permit is required, the following actions need to be completed to achieve compliance with the EPA standard:

• Initial sampling and testing
• Baseline Monitoring Report (BMR)
• Permit application
• Developing and certifying a TOMP plan
• Routine monitoring and reporting
• Permit renewals

PITFALL – Applicability of EPA Categorical Standard Not Assessed

From my experience, many manufacturing facilities have not fully disclosed with the local permitting authorities whether a discharge permit is required for the discharge of their wastewaters. Equally, local wastewater authorities are not always reviewing categorical requirements. As a result, the applicability of the metal finishing standard has also never been assessed. Issues tend to arise when a new inspector or other permitting agencies (i.e. State or EPA) get involved.

CONCLUSION

If you find that your facility does conduct one of the primary six metal finishing operations, work with your local permitting authority to obtain the required discharge permit. This will ensure compliance with the Metal Finishing Standard while also eliminating the possibility of EPA enforcement.

According to the latest statistics provided by OSHA, there were approximately 73,000 federal and state plan inspections that occurred throughout the 2018 fiscal year. Were you one of those companies? If so, how did your company fare during the inspection? Was your company prepared? OSHA inspections, like any regulatory inspection, can be positive experiences or they can go poorly. The state of your current safety program obviously plays a significant role in how successful you are at getting through an OSHA inspection without citations or penalties, but there are other points of consideration as well that can contribute to the outcome of the inspection. This article will focus on these elements.

The very first thing to be aware of is how – how does OSHA typically end up at a company’s front door?

TYPES OF OSHA INSPECTIONS

OSHA focuses its inspection resources on the most hazardous workplaces in the following order of priority:

OSHA’s updated recordkeeping rule expands the list of severe injuries that employers must report to OSHA. As of January 1, 2015, all employers must report the following:

1. All work-related fatalities within 8 hours.
2. All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours.

Note: Some state plans are different, see the state-specific guidelines.

The second thing to know and understand is what to expect during an OSHA inspection. The inspection process typically includes an opening conference, a program and training records review as they relate to the inspection, a walkthrough, employee interviews, and a closing conference. OSHA does not have to give advanced warning of an inspection. There are some rare circumstances, however, where they could. For example, it is possible they could provide advance notice to provide an employer with the opportunity to correct imminent danger hazards quickly.

ARRIVAL OF OSHA INSPECTOR AND OPENING CONFERENCE

You should always check an OSHA inspector’s credentials, which typically are presented upon arrival of the compliance officer. If unsure, get the inspector’s information (their business card is usually provided) and call the local OSHA office or the Department of Labor Office to confirm. There have been reported cases of scammers posing as OSHA inspectors, going to worksites and requesting payment of a fine. Understand that OSHA would never request immediate payment of a fine during an initial inspection.

During the opening conference, OSHA typically reviews the following with the employer:

• Purpose and scope of the inspection
• A copy of the complaint (if applicable)
• Process of the inspection (interviews, records, walk-through inspection, possible referrals and closing conference)
• Handouts – familiarity with OSHA
• Trade secrets guidelines
• Awareness of:
  • Recent inspections
  • Multi-employer worksites

RECORDKEEPING, WRITTEN PROGRAMS AND TRAINING RECORDS REVIEW

OSHA 300 logs tend to be the first thing reviewed by OSHA (and often go back five years) so be sure they are accessible and accurate. OSHA may choose to focus on a specific topic based on something observed on the log.

OSHA will likely request a review of certain required policies and training records. Be prepared in advance and have them organized in a known location. Do NOT give the inspector your entire safety policy and program records because they are likely only interested in the policies/programs that are related to the reason for their visit. Only show the programs and training records specifically requested by OSHA. Remember, this is not the time to ask all the questions about OSHA-related programs you have accumulated over the years.

WALKTHROUGH INSPECTION

During the walkthrough inspection portion of the OSHA visit, ensure that all members of the inspection party have appropriate personal protective equipment and that the inspector is always accompanied by a facility representative. The facility representative should be the same person throughout the inspection (two or more representatives could provide conflicting information). If at any time the facility representative has difficulty responding to a question, he/she should simply reply, “Let me get back to you on that. I don’t have all of the pertinent information at this time. I need to check with…” It is okay not to have all the answers or to politely and tactfully disagree. If you feel the inspector does not have an accurate perception or all of the facts, you can provide that information if you feel it works in your favor.

When walking through your plant, take them directly to the areas of interest rather than walking throughout the plant. Remember that anything you show them or anything they see during the walkthrough can be investigated further for potential violations. That is also a reason why you never want to leave the inspector alone. If OSHA takes notes, you should take notes. If OSHA takes a photo, you should take the same photo. And last but certainly not least, do not volunteer information during the walkthrough. Uncomfortable silences are better than talking too much (providing information that wasn’t asked for opens you up to further scrutiny).

CLOSING CONFERENCE

The inspector should describe the apparent violations that they will be recommending to their local office Area Director. They may set appropriate abatement periods (cannot extend past 30 days) and will typically advise you and the employee representative (if applicable) of their right to participate in any subsequent conference. If any alleged violations were corrected on the spot, the inspector must state that they were abated. The inspector should explain the penalty procedure, citation package and posting requirements, along with explaining the right to an informal conference and/or to contest any violations.

ADDITIONAL POINTS OF CONSIDERATION THAT CAN DETERMINE THE SUCCESS OF AN OSHA INSPECTION

There are several additional points to consider before and during an OSHA inspection that can be contributing factors to your overall success in completing the process with zero or minimal citations. First, and well before OSHA arrives at your door, your company must make a few important decisions. Determine ahead of time who will be contacted when OSHA shows up at your door, who’s in charge of gathering documents, who will accompany the compliance officer(s) during the walkthrough, etc. Your preparation should also include determining a union representative if the facility has union workers – especially if it’s part of a contract. Be sure to designate alternates for employees assigned to accompany an inspector.

Most safety professionals agree that employer attitude, organization, and good housekeeping all can make a positive impression during an OSHA inspection. If you are disagreeable, that can pass on to the compliance officer – your mood will affect their mood. An inspector can note an employer’s lack of cooperativeness on their report. Having easily located written safety records is imperative. If it takes you a half-hour to locate your lockout/tagout policy or an SDS, you are going to look disorganized and that could give the compliance officer the impression that your safety program is lacking or that you don’t have the required documentation.  Housekeeping is also very important. A dirty or cluttered workplace can immediately set the compliance officer off on the wrong foot. They may think to themselves, “If they can’t keep the floor and aisles clean, I wonder what else they haven’t been doing.”

The long unwritten rule with OSHA is: if it’s not in writing, it never happened. Besides standard safety training, document when your company does fire drills, safety committee meetings, brief toolbox talks, detailed incident investigations, safety improvements, etc. All of those things are just as important as safety training and you should get credit for them. They speak to your overall good faith, which is very important to convey during an OSHA inspection.

OSHA will typically wait a reasonable amount of time – up to an hour – before making note of any delays on the inspection report. This is the perfect time for employers to correct small hazards, such as making sure employees are wearing their applicable PPE, clearing areas in front of walkways, exit doors and fire extinguishers and assuring that forklift operators are wearing their seatbelts.

As a general rule, we don’t recommend refusing entry to OSHA. We have seen companies over the years with corporate policies that request a warrant for any government inspection. Quite frankly, that is a bad policy. Requesting to see a warrant before allowing an OSHA inspector to enter the workplace is likely to bring added scrutiny and suspicion. In most cases, they will get a warrant and will likely bring their most seasoned compliance officers who are very good at looking for possible OSHA violations.

Over the years, we have been through a lot of different OSHA inspections. We have seen common violations throughout these inspections, like safety records that are often overlooked by companies or those that they simply don’t have.  Here are a few of them:

• OSHA 300 Recordkeeping (properly filled out and current)
• Including temp workers on OSHA 300 logs
• Lockout procedure periodic inspections
• Forklift reevaluations
• Written PPE hazard assessments with certification
• Bloodborne pathogens training
• Hazardous chemical inventory list
• Hazard communication training for all employees
• Medical evaluations for all respirator users
• Annual respirator training and fit-testing

Finally, be proactive and honest. Developing an ongoing safety program with all of the required components is the best preparation. It eliminates anxiety over the unknown and allows you to feel comfortable about your employees and the company. You know that if you receive an OSHA inspection, you’ll be able to put your best foot forward. If you haven’t been keeping your safety program up to date, it will be too late by the time OSHA shows up. Be honest in your answers because OSHA will know if you’re faking it. They will be happy to work with you if they feel you are genuine, doing your best and have the best interest of your employees in mind.