When you think of Top Ten lists these days, comedy is the first thing that comes to mind. But if OSHA arrives on your jobsite, good jokes won’t get you very far. You need to prove that your company and employees are serious about safety. The most important thing to remember before a compliance officer appears on your worksite is to be prepared. There is little you can do in way of documentation when OSHA is already in the job trailer. Preparation is the key!
In this article, we’ll cover the ten documents and reports that are asked for most often when visiting construction sites.
1. Injury/illness records -- Your OSHA 300 log and OSHA 300A or 300 Summary should be up to date and available or at least accessible from your home office. The 300 Summary is required to be posted February 1st through April 30th, so depending on the time of the inspection, the compliance officer may inquire where the 300A is posted.
2. Written Programs -- Depending on the tasks being performed by your company at the jobsite, various written programs are required and may be requested. Hazard Communication is a program that is required by all employers who use chemicals/hazardous materials. Fall Protection, Confined Space, Lockout Tagout and Excavation/Trenching are all examples of tasks that need written programs. These programs should contain the specific steps or procedures to complete the task(s) safely.
3. Material Safety Data Sheets -- Your company should have a MSDS for every chemical/material onsite or be quickly accessible from your company office. Employee accessibility and the method of maintaining these sheets may be asked by the compliance officer. This information should be included in the hazard communication policy.
4. Training/Certification Records -- Depending on the jobsite and the tasks being performed on the job, the compliance officer may request proof of training for various types of work. This may cover hazard communication training to lockout tagout, excavation, or forklift training.
5. Competent/Qualified Person Inspections -- The inspections by competent/qualified persons required by some regulations should be accessible if requested by the compliance officer. Some tasks requiring competent/qualified persons are scaffolding, excavation/trenching, confined space entry, forklifts, elevated work platforms, etc.
6. Chemical Inventory -- A list containing the names of all the chemicals/hazardous material used by the employer is required. This requirement is part of the hazard communication program and may be contained with the Material Safety Data Sheets or in the hazard communication policy.
7. Hazard Assessment -- A written hazard assessment identifying hazards/tasks that require the use of personal protective equipment may be requested to be reviewed. This may be covered in Job Safety Analysis or other similar documents.
8. Emergency Action Plan -- Written plans are required for each worksite to address what actions jobsite personnel should take in case of an emergency such as severe weather, earthquake, fire, or chemical release. Your employees should know the procedures for each type of emergency and be able to follow these.
9. Required Postings -- The Department of Labor required postings should be located in an area that is accessible to employees and is easily visible.
10. Jobsite Safety Documents -- These documents may include required hot work or confined space permits. Other documents, such as a Daily Safety Plan or a daily Job Safety Analysis may be requested for review.
One more point, while it’s important to have the right information on hand, and to be responsive when the OSHA inspector asks for more detail or clarification, never feel compelled to volunteer information that the inspector hasn’t requested.