In the past, OSHA was considered a collaborator—a resource available for answering questions, helping solve hazard problems and generally working with employers to create safe, secure work environments. All of this is changing. OSHA has taken on a new enforcer persona. Since the Obama administration has assumed authority, OSHA has seen a 13.45% increase in their budget and 12.92% increase in their FTE¹ . This is gearing the agency up to send more investigators into the field to find non-compliant employers and fine them.

These changes are not necessarily a bad thing, especially if you are safety diligent, following regulations, and keeping good records. Keeping employees safe is always the right thing to do. But more than ever, just keeping employees safe will not be enough. All employers, no matter the industry, need to review Safety Programs, check recordkeeping, and prepare for the OSHA inspection before it happens.

Record-keeping and tracking your training programs

The original 1970 Occupational Safety and Health Act focused on the safety of every American worker no matter their workplace environment. Since then, several other key pieces of legislation have enhanced the scope of the original bill including:

• Cardiac Arrest Survival Act 2000
• Sarbanes-Oxley Act 2002 (whistleblower protection)
• Corporate Injury, Illness and Fatality Reporting Act of 2009

Employers are tasked with more than just providing a safe work environment. Responsibilities include annual reporting of workplace injuries along with regular training of your employees in workplace safety:

• Blood Borne Pathogens Standard
• Hazardous Communication Standard
• Noise Standard and Hearing Conservation
• Shut down / lock out
• Material safety data sheet maintenance

These are just a few of the training responsibilities for which you must maintain current and accurate records. Record keeping scrutiny is likely to increase with fines for non-compliance in companies never before investigated by OSHA. Make safety record keeping, training, and tracking a priority. Review your Safety Plan manuals with a focus on Personal Protective Equipment, procedures on responding to emergencies and updating emergency evacuation plans.

Be prepared for an inspection before it happens:

1. Review OSHA standards and determine which apply to your company.
2. If you have had a previous inspection, be prepared to produce the reports and responses to any citations that may have been issued.
3. Train your receptionists or front door greeters in how to respond to an inspector.
4. Predetermine who in the company should accompany the inspector through out the process and make that part of employee training.

When the inspector, knocks at your door be courteous, but answer only the questions asked, provide only the data requested and remember to ask when you can expect a written summary of the inspection before the inspector leaves.

As an employer you want to be able to demonstrate a commitment to safety beginning at the worksite and extending to the C-suite. Documentation alone won’t win the battle. When everyone walks the safety talk, everyone is victorious.