When the front entry door opens to your business, and one or two compliance officers from the Occupational Safety and Health Administration (OSHA) walk in, it’s important that your business is prepared for an inspection. In this article, we will discuss the types of inspections, what to expect, what documentation you will need, how to work with the compliance officer, and the appeals process.
Types of Inspections:
OSHA inspections are based on the following categories:
- Imminent danger situations – hazards that could cause death or serious physical harm receive top priority.
- Severe injuries and illnesses:
o All work-related fatalities
o All work-related inpatient hospitalizations, amputations, or losses of an eye
- Worker Complaints – Allegations of hazards or violations also receive a high priority. Employees may request anonymity when they file complaints.
- Referrals – Reported hazards from other federal, state or local agencies, individuals, organizations or the media.
- Targeted inspections – Inspections aimed at specific high-hazard industries or individual workplaces that have experienced high rates of injuries and illnesses also receive priority.
- Follow-up inspections – Checks for abatement of violations cited during previous inspections are also conducted by the agency in certain circumstances.
- National Emphasis Programs (NEPs) – These programs temporarily focus enforcement resources on specific hazards.
NEP program examples:
o Heat-Related Hazards NEP: Inspects workplaces to ensure plans for preventing heat-related illnesses are implemented.
o Amputations NEP: Targets manufacturing facilities to ensure compliance with safety practices, including energy control and machine guarding.
In May of 2025, OSHA began its Site-Specific Targeting Program (SST). This program utilizes information gathered from the employer’s injuries and illnesses for the prior years. OSHA uses the information gathered from all reported injuries and illnesses from 2021 through 2023. This helps direct inspectors to the highest-risk establishments. Those companies that have worker compensation codes related to high-risk job tasks, and have experienced a trend in accidents will be a focus point for the SST program.
What to Expect:
OSHA is not required to provide prior notice of an inspection. Compliance officers can show up at any worksite and at any time of day. Telling a compliance officer that it’s a bad day or time for an inspection won’t do you any good. I’ve been through countless inspections with OSHA, and convenience does not factor in.
Preparation
Before conducting an inspection, OSHA compliance officers research the inspection history of a worksite using various data sources, review the operations and processes in use and the standards most likely to apply. Assigned worker compensation codes are reviewed in order to understand the various tasks performed at the workplace. They will gather appropriate personal protective equipment and testing instruments to measure potential hazards.
Presentation of credentials
The on-site inspection begins with the presentation of the compliance officer’s credentials, which include both a photograph and an identification number.
Opening Conference
The compliance officer will explain why OSHA selected the workplace for inspection and describe the scope of the inspection, walkaround procedures, employee representation and employee interviews. The employer then selects a representative to accompany the compliance officer during the inspection. An authorized representative of the employees, if any, also has the right to accompany an inspector. The compliance officer will consult privately with a reasonable number of employees during the inspection. I prefer having a safety committee member, or the committee chairperson accompany the OSHA compliance officer. Committee members will have a better understanding of the safety program policies and procedures, and be able to answer questions that arise.
Walkaround
Following the opening conference, the compliance officer and the representatives will walk through the portions of the workplace covered by the inspection, inspecting for hazards that could lead to employee injury or illness. The compliance officer will also review worksite injury and illness records and the posting of the official OSHA poster.
During the walkaround, compliance officers may point out some apparent violations that can be corrected immediately. While the law requires that these hazards must still be cited, prompt correction is a sign of good faith on the part of the employer. Compliance officers try to minimize work interruptions during the inspection and will keep confidential any trade secrets observed.
Closing Conference
After the walkaround, the compliance officer holds a closing conference with the employer and the employee representatives to discuss the findings.
The compliance officer discusses possible courses of action an employer may take following an inspection, which could include an informal conference with OSHA or contesting citations and proposed penalties. The compliance officer also discusses consultation services and employee rights. Employers have 15 working days after receipt of citations and proposed penalties to formally contest the alleged violations and/ or penalties by sending a written notice to the Area Director.
Documentation
Being prepared is something that you can’t do at the last moment. Preparation through documentation is constant throughout the year. The better prepared you are, the better the results will be. Acting difficult, frustrated or getting upset will cause more harm than good.
The following documentation should always be present and available for review by an OSHA compliance officer:
- OSHA 300 Log: The OSHA 300 and 300A forms are the employer’s summary of the workplace’s injuries and illnesses. This OSHA 300 form must be completed each year by the employer, listing all recordable injuries and illnesses experienced during the calendar year. The 300A summarizes the number of injuries and illnesses, any deaths, the number of days away from work, and the number of days with job transfer or restriction.
- Injury and Illness Investigations: Each recordable injury or illness must be investigated by the businesses management and/or the business’ safety committee. The investigation identifies your findings regarding the incident, a root cause and steps taken to prevent a reoccurrence.
- Written Workplace Safety Programs: The compliance officers will want to review your written safety programs. You must have a written program for those required in accordance with the tasks performed in your workplace. You may combine a couple programs, but you will need to cover the related OSHA Standard requirements.
These programs may include:
o Written Bloodborne Pathogen Exposure Control and Universal Precautions program
o Written Confined Space Entry Program
o Written Crane / Hoisting Program
o Written Electrical Safety Program
o Written Emergency Action Plan Program
o Written Equipment Operational Safety Training Program
o Written Ergonomics Program
o Written Fire Safety and Prevention Program
o Written Fall Protection Program
o Written First Aid Emergency Program
o Written Fleet and Driving Safety Program
o Written Forklift Operational Safety Program
o Written General Safety and Health Provisions
o Written Hazard Communication Program / Globally Harmonized System
o Written Hearing Conservation Program
o Written Hot Work Program
o Written Lockout/ Tagout / Control of Hazardous Energy Program
o Written Machine Guarding Program
o Written Personal Protective Equipment Program
o Written Respiratory Protection Program
- Safety Meeting Minutes: Each safety committee meeting must be documented. Documentation must include:
o Date of meeting
o New business
o Notes
o Committee members in attendance
- Safety Training Documentation: Documentation, training and having the right policies are critical. It’s also important that you never provide more information than requested. As with law enforcement, violators often provide information that leads to further citations. All employee safety training must be documented. As I’ve mentioned many times, there is no use providing the training if you don’t document it. The documentation should include the topic, notes, training methods, and the name or signature of those present. Safety training must be provided in accordance with the specific job tasks performed. Training must be provided previous to the employee’s initial assignment and at least annually thereafter.
How to Work with an OSHA Compliance Officer
My best recommendations for working with a compliance officer are to be friendly, professional, compliant and honest.
Being a jerk when dealing with OSHA will only make things worse. I’ve dealt with some of the friendly and professional OSHA personnel, and I’ve dealt with those that were unfriendly, overbearing and arrogant. Treat them as you would want to be treated. They have a very important job to do, and how easy it is overall is normally driven by the attitude of the business management staff. I recommend that you allow them to review anything they request to see and never tell them that you’re not willing to unlock a door or toolbox, or allow them to talk to an employee. There is nothing off limits of their review and restricting them will only cause you more problems.
I also recommend that you have someone of authority and knowledge to accompany them in their inspection. Someone that can address concerns immediately and in the compliance officer’s presence. You may not get out of a citation, but addressing it immediately shows them that you’re willing to comply, and this may result in a reduction in fines.
It’s important that you never provide more information than requested. As with law enforcement, violators often provide information that leads to further citations. Answer questions, but don’t ramble or provide extra information.
As an example: The compliance officer asks about a particular building, and you tell them what they want and inform them that you also have buildings at another location that they are not aware of. Remember, be precise with your answer, but don’t elaborate further than the answer requested.
Appeals
When OSHA issues a citation to an employer, it also offers the employer an opportunity for an informal conference with the OSHA area supervisor to discuss citations, penalties, abatement dates, or any other information pertinent to the inspection. The agency and the employer may work out a settlement agreement to resolve the matter and to eliminate the hazard. OSHA’s primary goal is correcting hazards and maintaining compliance rather than issuing citations or collecting penalties. I recommend that you always file an appeal for high-cost citations when you feel you deserve a better outcome. Citation amounts increased in 2025 and are not a hundred dollars anymore. Citations are in the thousands now. As stated previously, addressing the concern immediately may result in a reduction in the amount of the fine.
Lastly, having a proactive safety training program protects employees from injury and illness, saves money in insurance rates, and prevents citations when an OSHA compliance officer walks through your entry door. When OSHA arrives, it’s too late to scramble and get your required documentation in order. Keep up with your safety training and training files, operate your business in accordance with OSHA standards, ensure your 300 logs are up to date, investigations are completed, safety programs are in place, and your safety committee minutes are available for review.
Trust me, OSHA compliance officers have been lied to before. They’re well trained and know how to deal with a workplace that isn’t forthcoming. When they find that you’re not current with the required training and/or documentation, you’ve put your workplace in a very precarious situation.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products’ sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com. When it comes to appealing a citation, depending on the size of the fine, you may want to bring in a safety lawyer who can help negotiate the process. A lawyer who is very familiar with pallet and sawmill issues is Adele Abrams who has worked for years with pallet companies and the NWPCA. She can be reached at https://www.littler.com/people/adele-abrams.
