What to Do When OSHA Requests Documentation

What might OSHA request during an inspection

If your company is visited by OSHA, for any reason, there is a very strong chance that they will be requesting to look at your Written Safety Plans/Programs, as well as necessary documentation for their visit. The lack of up to date and site-specific Written Safety Plans/Programs and other documentation is a leading cause of OSHA citations.

With maximum limits for OSHA fines increasing yearly (now over $16,100 per violation for serious/other than serious citations and more than $161,000 for a repeat and willful), planning ahead for an OSHA inspection and ensuring your documentation is compliant with regulatory requirements and readily accessible can help avoid citations and fines.  If your company is ever visited by OSHA, for any reason, please contact your ACS Account Manager right away for assistance.

Documentation includes, but is not limited to, Written Safety Plans/Programs, Training Records, past Safety Inspections and Corrective Actions, Injury/Illness Forms/Records (OSHA 300 Log, 300A Summary, 301 Incident Report or equivalent form), Accident/Incident Investigations, Medical Records (audiometric testing, medical exams, etc.), Exposure Records (chemical exposure, noise exposure, etc.), Hazardous Chemical List, Respirator Fit Test Records, Standard Operating Procedures, Equipment Operator Performance Evaluations, Hot Work Permits, Confined Space Entry Permits, Eyewash and Safety Shower Inspection Records, Portable Fire Extinguisher Inspection & Servicing Records, Equipment Maintenance & Inspection Records, etc.  What documentation OSHA requests varies based on the type of inspection, but Written Safety Plans/Programs, Injury/Illness Forms/Records, and Training Records are almost always requested. Documentation requests are made to the employer during the opening conference of an inspection.  They may also make a request via email or in writing after the inspection or during an investigation of an employee complaint. 

How ACS helps your company stay in compliance with Written Safety Plans/Programs

ACS provides our CMS clients with Written Safety Plans/Programs and many forms to document your safety and compliance efforts. It should be noted that each Written Safety Plan/Program that ACS provides requires specific implementation measures such as designating a person(s) responsible for overseeing the plan/program, training employees, maintaining applicable records, and designating individuals for tasks or listing detailed processes for carrying out procedures detailed within the document.  ACS provides completion guidelines with each Written Safety Plan/Program to help with your implementation process.

Certain changes in the workplace can affect the accuracy of your Written Safety Plans/ Programs including changes in personnel, procedures, materials, processes, equipment, new construction, etc. Therefore, it is important to annually review your plans/programs and update them accordingly, particularly when any of these changes occur.  ACS will work with you to update your plans/programs and will often reach out to you to start the plan update process.

Always be prepared for an OSHA inspection in case such a situation occurs by having up to date plans/programs and other documentation to show your safety and compliance efforts.

If you need to update your plans/programs, contact ACS today at clientservices@acs-safety.com.