Safe Work Procedure: OSHA Visit

Document Number: [SWP-NUMBER] Revision Date: [DATE] Next Review Date: [NEXT REVIEW DATE] Department: [DEPARTMENT NAME]

1. Scope

This Safe Work Procedure (SWP) outlines the steps to be taken by American Refrigeration Services (ARS) employees and representatives during an OSHA (Occupational Safety and Health Administration) inspection. This procedure applies to OSHA inspections occurring at:

Customer sites where ARS is performing work for another company.
Customer sites where ARS is the primary employer.
American Refrigeration Services branch locations.

This SWP aims to ensure compliance with OSHA regulations, protect the rights of both employers and employees, and facilitate a smooth and professional inspection process. It covers procedures from the initial arrival of the OSHA Compliance Safety and Health Officer (CSHO) through the closing conference. This SWP should be used in conjunction with the OSHA Field Operations Manual (FOM) and other relevant OSHA guidelines.

2. Definitions

CSHO (Compliance Safety and Health Officer): An OSHA representative authorized to conduct inspections and investigations to determine whether employers are complying with occupational safety and health standards and regulations.

Opening Conference: The initial meeting between the CSHO, employer representatives, and employee representatives (if any) at the start of an OSHA inspection .

Walkaround: The physical inspection of the workplace conducted by the CSHO, accompanied by employer and employee representatives, to identify potential hazards and violations .

Closing Conference: A meeting held at the conclusion of an OSHA inspection to discuss findings, apparent violations, and other pertinent issues with the employer and employee representatives .

Multi-Employer Worksites: Workplaces where multiple employers are present, potentially leading to shared responsibility for safety and health violations .

3. Responsibilities

3.1 Supervisors

Ensure all employees are aware of this SWP and their roles during an OSHA inspection.
Designate a management representative to accompany the CSHO during the inspection.
Cooperate with the CSHO while also protecting the company's interests and rights.
Take immediate action to correct any hazards identified during the inspection.

3.2 Workers

Cooperate with the CSHO and provide accurate information when interviewed .
Report any safety or health concerns to the supervisor or designated representative.
Exercise their right to participate in the inspection through an employee representative .
Understand their rights under Section 11(c) of the OSH Act, protecting them from retaliation for raising safety concerns 3, 4.

3.3 Health and Safety Representative

Act as a liaison between employees and management during the inspection.
Ensure employee concerns are addressed and communicated to the CSHO.
Participate in the opening and closing conferences.
Accompany the CSHO during the walkaround to point out potential hazards and areas of concern.

4. Potential Hazards and Risks

Hazard	Risk	Control Measures
Unexpected OSHA Inspection	Disruption of work, potential for penalties	Have a prepared plan and trained personnel.
Confined Spaces	Asphyxiation, toxic exposure, fire/explosion	Follow confined space entry procedures, ensure proper ventilation and monitoring .
Hazardous Materials	Chemical burns, respiratory illness, environmental contamination	Use proper PPE, follow SDS guidelines, ensure proper storage and handling .
Workplace Violence	Physical harm to employees and CSHO	Implement workplace violence prevention programs, provide training to employees .
Trade Secret Disclosure	Loss of competitive advantage	Identify and protect trade secret areas, inform CSHO of confidentiality requirements .
Slips, Trips, and Falls	Injuries to employees and CSHO	Maintain clear walkways, use appropriate footwear, address spills immediately.
Ergonomic Hazards	Musculoskeletal disorders	Use proper lifting techniques, provide ergonomic workstations, implement stretching programs.

5. Personal Protective Equipment (PPE)

Proper PPE must be worn at all times to minimize the risk of injury or illness. All PPE must be inspected before use to ensure it is in good condition.

Hard Hat - Protects the head from falling objects and impacts.
Safety Glasses - Protects the eyes from dust, debris, and chemical splashes.
Gloves - Protects the hands from cuts, abrasions, and chemical exposure.
Safety Shoes - Protects the feet from impacts, punctures, and electrical hazards.
High-Visibility Vest - Ensures visibility in low-light conditions and around moving equipment.
Respirator - Protects against airborne contaminants (if required based on hazard assessment) .

6. Equipment and Tools

Ensure all equipment and tools are in good working condition and used according to manufacturer's instructions.

Air Monitoring Equipment - Used to detect and measure airborne contaminants (if required).
Sound Level Meter - Used to measure noise levels in the workplace (if required).
Camera/Video Recorder - Used to document potential hazards and violations 7, 8.
Measuring Tape/Wheel - Used to measure distances and dimensions for compliance purposes.
Computer/Tablet - Used to access safety data sheets (SDS), regulations, and other relevant information.

7. Pre-Job Requirements

7.1 Training and Competency

All employees must receive training on this OSHA Visit SWP.
Supervisors and designated representatives must receive additional training on OSHA regulations and inspection procedures.
CSHOs must be trained and certified in accordance with OSHA requirements .

7.2 Pre-Job Briefing

Before any OSHA inspection, conduct a pre-job briefing with all relevant personnel.
Review the scope of the inspection, potential hazards, and control measures.
Assign roles and responsibilities to team members.
Ensure all personnel understand the communication protocols and emergency procedures.

7.3 Work Area Preparation

Ensure the work area is clean, organized, and free of hazards.
Make sure all equipment and tools are in good working condition.
Have all relevant documents readily available, including safety data sheets (SDS), training records, and inspection reports.
Prepare a designated area for the CSHO to conduct interviews and review documents.

8. Safe Work Procedure Steps

8.1 Upon Arrival of the CSHO

Step 1: Greet the CSHO professionally and request identification .
Step 2: Notify the designated management representative and employee representative (if applicable).
Step 3: Escort the CSHO to a designated waiting area.

Safety Considerations: Maintain a professional and respectful demeanor at all times.

8.2 Opening Conference

Step 1: Attend the opening conference with the CSHO, management representative, and employee representative (if applicable) 8, 9.
Step 2: The CSHO will present credentials, state the purpose of the visit, and explain employer and employee rights .
Step 3: Inquire about the scope of the inspection and any specific areas of concern .
Step 4: Inform the CSHO if there are areas containing trade secrets and the company's policy regarding confidentiality .
Step 5: Provide requested documents, such as OSHA 300 logs, 300A summaries, and 301 incident reports, within the required timeframe 6, 12.

Safety Considerations: Ensure all participants understand their rights and responsibilities during the inspection.

8.3 Walkaround Inspection

Step 1: Accompany the CSHO during the walkaround inspection, along with the designated representatives .
Step 2: Take detailed notes of all observations and any potential violations identified by the CSHO.
Step 3: Point out any existing safety measures and controls in place.
Step 4: Address any immediate hazards identified by the CSHO, if possible .
Step 5: Ensure the CSHO complies with all safety rules and practices of the establishment .

Safety Considerations: Avoid interfering with the inspection, but ensure the CSHO is aware of all relevant safety measures.

8.4 Employee Interviews

Step 1: Cooperate with the CSHO in arranging private employee interviews, if requested .
Step 2: Inform employees of their right to speak freely and without fear of retaliation 3, 4.
Step 3: If an employee requests union representation or legal counsel, honor the request and consult with the Area Director if necessary .

Safety Considerations: Do not interfere with the CSHO's ability to conduct private interviews with non-managerial employees.

8.5 Closing Conference

Step 1: Attend the closing conference with the CSHO, management representative, and employee representative (if applicable) .
Step 2: Discuss the apparent violations and other pertinent issues found during the inspection .
Step 3: Take notes on the CSHO's findings and proposed corrective actions.
Step 4: Obtain a copy of the "Employer Rights and Responsibilities Following a Federal OSHA Inspection" publication .
Step 5: Understand the company's rights and responsibilities, including the right to contest citations and penalties .

Safety Considerations: Ensure all participants understand the findings and have the opportunity to ask questions.

9. Precautions and Safety Measures

Professional Conduct: Maintain a professional and respectful demeanor throughout the inspection process . Explanation: This helps to establish a positive working relationship with the CSHO and ensures a fair and objective inspection.
Accurate Information: Provide accurate and truthful information to the CSHO at all times. Explanation: Providing false or misleading information can result in additional penalties and legal consequences.
Documentation: Keep detailed records of all interactions with the CSHO, including notes, documents, and photographs. Explanation: This documentation can be valuable in the event of a dispute or legal challenge.
Confidentiality: Protect confidential information, including trade secrets and employee medical records . Explanation: Ensure that only authorized personnel have access to sensitive information and that it is not disclosed to the CSHO without proper authorization.
Legal Counsel: Consult with legal counsel if you have any concerns about the inspection process or potential violations. Explanation: An attorney can provide guidance on your rights and responsibilities and help you navigate the legal complexities of an OSHA inspection.

10. Emergency Procedures

10.1 General Emergency Response

In the event of an emergency, such as a fire, explosion, or serious injury, immediately evacuate the area and contact emergency services.
Follow the company's emergency action plan and procedures.
Notify the CSHO of the emergency and cooperate with their instructions.

10.2 Specific Emergency Scenarios

Medical Emergency: Provide first aid and contact emergency medical services. Response procedure: Ensure the injured person receives prompt medical attention.
Fire: Activate the fire alarm and evacuate the building. Response procedure: Follow the company's fire safety plan and procedures.
Hazardous Material Release: Evacuate the area and contact the HazMat team. Response procedure: Follow the company's hazardous material spill response plan.

10.3 Emergency Contact Information

Emergency Services: 911
[Company Safety Officer Phone Number]
[Local Hospital Phone Number]

11. Incident Reporting and Investigation

Any incidents, near-misses, or hazards identified during the OSHA inspection must be reported to the [Designated Contact Person] immediately.
The [Designated Department] will conduct a thorough investigation of all reported incidents to determine the root cause and implement corrective actions.
All findings and corrective actions will be documented and shared with relevant personnel.

Approved by: [NAME AND POSITION] Date: [APPROVAL DATE]