Top Ten Documents OSHA Expects to See
By Safety Management Group
Top Ten lists can be funny, but when it comes to OSHA, most contractors aren’t in a humorous mood. When state or federal safety inspectors arrive on your site, it’s up to you to prove that your company and your employees take safety seriously. And, because you won’t have time to develop a good presentation, you’ll want to make sure you’re always ready for that surprise visit.
One particularly effective way to do that is to make sure that you have easy access to the ten documents and reports that OSHA inspectors normally ask to see when they’re on a construction site. Being able to produce them instantly tells the inspector that you share his or her concern about safety, which may mean a less-intense and less-adversarial inspection.
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 quickly from your home office). The 300 Summary must 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. 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 able to access them quickly). The compliance officer may ask about employee accessibility and the method of maintaining these sheets, and that information should be already included in your hazard communication policy.
4. Training/Certification Records
Depending on the jobsite and the tasks being performed, the compliance officer may request proof of training for various types of work. This may cover hazard communication, 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. Tasks that may require competent/qualified persons include scaffolding, excavation/trenching, confined space entry, forklifts, and elevated work platforms.
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. This may be covered in the Job Safety Analysis or 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.
Finally, 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.