Surprise inspections are a reality faced by businesses across a wide range of countries and industries. There’s always a lot riding on your ability to make a good impression on the person who knocks on your door with a checklist and a clipboard. What’s at stake will vary, but workplaces often face the prospect of fines, loss of customer business, damage to company reputation, and even prosecutions.
With all of this in mind, being prepared to the best of your ability is vital!
Know the Odds
What is the likelihood that an inspector will arrive at your workplace tomorrow? If they do, what will they be looking for? The more accurately you can answer these questions, the more likely it is that you’ll be ready if they do show up!
There are several pieces of information you can use to predict the odds of being targeted for a surprise inspection. To start, if you answer yes to any of these questions you should be on high alert:
- Workplace History: Does your workplace have a history of worker injuries or compliance issues?
With so many businesses and only so much time, inspectors must focus their attention on workplaces where workers are deemed to be at the greatest risk of injury. For this reason, companies that have reported a high number of injuries or severe injuries, or who have been flagged for compliance concerns in the past, are most likely to be visited by an inspector.
- Industry Safety Record: Does your business belong to an industry with a poor safety record?
This will often be determined by your SIC code. Industries such as construction, petrochemical and generic chemical production, food processing, textiles, and heavy manufacturing have high rates of incidents and are therefore more likely to be the victims of surprise inspections.
- Worker Attitudes & Perceptions of Company Safety Performance: Do you have a healthy safety culture, and do your workers feel they can come to you with safety concerns?
A large number of site visitations are prompted by employee (or former employee) complaints that allege serious safety violations. In fact, in the United States over half of OSHA surprise inspections are triggered by employee complaints. One way that you can attempt to prevent a complaint-triggered inspection at your business is to start an in-house complaint program of your own. Encourage employees to anonymously report potential violations or safety hazards to you, rather than to the governing body.
Understand the Inspector’s Priorities
Whether you are under the jurisdiction of the Occupational Safety and Health Administration (OSHA) in the United States, the Ministry of Labour (MOL) in Canada, the Health and Safety Executive (HSE) in the UK, or any other health and safety regulator, there is often publicly available information about their current inspection priorities. It is well worth your time to check this out as it can help you set your own internal safety priorities.
OSHA, for example, conducts targeted enforcement initiatives (such as the current Temporary Worker initiative) as well as national and local emphasis programs that are strategies intended to address hazards or industries that pose a particular risk to workers within specific jurisdictions. For instance, poultry production in the southeast and oil companies in the southwest. Maintaining awareness of these initiatives, along OSHA’s annual list of the Top Ten Most Frequently Cited Standards can give companies in the U.S. a head start when it comes to preparing for a surprise inspection.
Similarly, within Canada there are many inspection “blitzes” that focus on sector-specific hazards. These blitzes or enforcement initiatives are conducted by the provincial authorities, such as WorkSafeBC in British Columbia and the Ministry of Labour in Ontario, and information on these priorities can typically be found on their websites. The Health and Safety Executive (HSE) in the UK also lists information about their sector strategies on their official website.
Get Organized – Before the Inspection!
If you wait until the inspector shows up to pull everything together, you will be stuck in defense or reaction mode. Ensuring that all of your compliance documentation is in order is critical to performing well in an inspection. Depending on the size of your business or the complexity of your compliance activities, you may need to evaluate whether your current system is up to the task of passing a surprise inspection. You don’t want to be rifling around frantically for a misplaced file with an inspector lingering over your shoulder.
Use this information as a starting point for developing a comprehensive surprise inspection plan, and you’ll feel confident in the knowledge that when an inspector comes knocking, you won’t be caught unprepared!
To learn about two recently announced mining inspection initiatives in the US and Canada, check out the July 11, 2014 edition of of Intelex’s EHS This Week podcast. Listen to our podcast weekly for the top headlines and issues affecting the world of environment, health and safety!