Opening Conference

  • Select date

  • Client asks for credentials

  • Client asks purpose of visit

  • Time to get to meeting room

  • Time frame for wait is reasonable

  • Location of meeting room

  • Meeting room is appropriate. Location and pathway acceptable and unrevealing.

  • Names and Titles of all present

  • Is the facility Union

  • Union Name/ Number

  • List of representatives

  • Did Union request to be present

  • Does Employer host other employees on premises

  • Names of alternate employers

  • Name of Alternate employer representatives

  • Do alternate employer representatives request to be present

  • Does client have written protocol for handling OSHA inspection

  • What is NASIC code or SIC code according to Employer

  • Is contact information on OSHA web site correct

  • Enter correct Information

OSHA Log Review

  • Are OSHA logs for previous 5 years available for review

  • Are 300 A available for previous years

  • Current Year Log Completed Properly

  • Describe Violations

  • Is current 300A completed properly including signatures

  • Describe violations

  • Current Year Recordable Rate

  • Current year DART Rate

  • Current Year Lost Time Rate

  • Is Previous Year Log completed properly

  • Describe violations

  • Are violation within the past 6 months

  • Issue Violation

  • Is Previous year 300A completed properly including signatures and proof of posting

  • Previous Year recordable Rate

  • Previous Year DART Rate

  • Previous Year LT rate

  • Are their any trends indicated on the OSHA logs

  • List Trends

  • REVIEW medical data to validate days counted

  • List any recordkeeping violations

Written Policies/ Procedures

  • Does Client have a safety manual

  • ASK for Copy

  • Select OSHA Written Programs

  • List Special / Other Policies or Programs

  • Are policies current or reviewed annually if required

  • List Out of Date Policies

Safety and Health Program

  • Are JSA’s completed for each job, reviewed annually, and available in Spanish?

  • Is there an active Safety Committee meeting monthly with appropriate representation?

  • Are safety committee meetings frequent enough and do they cover appropriate information? Review minutes

  • Do people receive safety orientation on the hazards of their job (documented)?

  • Do people acknowledge orientation by signing an Orientation Form?

Required Posting/Recordkeeping (1904.)

  • Is the required OSHA workplace poster displayed in a frequented area of the workplace where all employees are likely to see it?

  • Is the summary of Occupational Illnesses & Injuries posted in the month of February through April?

Medical Services and First-Aid (1910.151)

  • Is there a hospital, clinic, or physician designated for injury care?

  • Are first-aid kits equipped for bloodborne pathogens with rubber gloves and antiseptic wipes?

  • Are eye wash stations and safety showers located where chemicals are dispensed, functional, accessible, and checked frequently monthly?

  • Is there first-aid equipment or facilities available for treating minor injuries?

  • Are first-aid cases logged and described?

  • Have people been trained in first aid that renders treatment to the injured?

  • Are First Reports of Injuries being properly filled out and distributed?

Bloodborne Pathogens (1910.1030)

  • Is PPE available to First Responders?

  • Are waste receptacles available and identified?

  • Is training given to First Responders annually (documented)

  • Are vaccinations offered to First Responders? (See the records of those who received shots and denial forms of those who did not.)

Process Safety Management (1910.119) Regulated Chemical(s)

  • Is facility subject to RMP (EPA)

  • Has plan been submitted to appropriate authority?

  • Is client subject to PSM or practicing PSM

  • Has initial and refresher training (3 yrs) been provided to operating employees?
    (Review training records)

  • Are there written operating procedures for the process?

  • Has a compliance audit been conducted in the last 3 years to verify that procedures
    and practices are still adequate and being followed?

  • Has a process hazard analysis been completed and documented within 5 years? What methodology was used

  • Were Pre-start up safety reviews performed?

  • Are there written procedures to maintain the mechanical integrity of the equipment?

  • Is there a comprehensive Contractor Safety Plan?

  • Are hot work practices followed when working on or near the process?

  • Is there a Management of Change program in place?

  • Is there an incident Investigation plan in place?

  • Have there been any incidents?

  • Review Incident Investigation: Have all corrective action measures been addressed and completed?

  • Is there an emergency plan and trained response team for chemical releases?

  • Has team been trained and do they document mock drills on a regular basis?

  • Is the plan reviewed and updated (if needed) every 5 years, quarterly by mgmt?

Exiting or Egress (1910.35, .36, .37)

  • Are exits marked with an exit sign and illuminated by a reliable light source?

  • Is there an Emergency Action Plan for weather, fire, and medical emergencies?

  • Are emergency plans communicated to all employees (documented)?

  • Are all exits kept free of obstructions inside and out?

  • Are key personnel trained in responsibilities (documented)?

  • Does the Plan contain an Emergency Call List with phone numbers?

  • Are storm shelters identified?

  • Is accountability of employees established for evacuation purposes?

  • Is their sufficient emergency lighting?

  • Have regular evacuation and/or severe weather drill been conducted?

  • Are exit doors able to open from the direction of exit travel without the use of a key or any special knowledge or effort when the building is occupied?

Walkways/Railings (1910.23)

  • Are aisles and passageways kept clear, identified, and crosswalks visible to area traffic?

  • Are holes in the floor, grates, sidewalk, or other walking surface repaired promptly, covered or otherwise made safe?

  • Are all rugs or floor coverings in good condition and without holes or trip hazards?

  • Are pits and floor openings covered or otherwise guarded?

  • Are railings provided where there is a drop from one elevation to another?
    (railings – 42” high with midrail – toe board for people exposure below.)

  • Are railings in good condition?

  • Are there documented regular inspections of Walking Working Surfaces?

Portable/Fixed Ladders (1910.26, .27)

  • Are all ladders maintained in good condition, joints between steps and side rails tight, all hardware and fittings securely attached and moveable parts operating freely without binding or undue play?

  • Are non-slip safety feet provided on each ladder and rungs provide good footing?

  • Is a monthly inspection completed for ladders along with employee training on the safe use?

  • Are portable ladders secured when stored to prevent tipping/falling?

PPE (1910.132, .133, .135, .136)

  • Has workplace hazard assessment been completed and accurately maintained?

  • Have the employees been trained in the use, maintenance, and limitations of personal protective equipment (documented)?

  • Are protective goggles or face shields provided and worn when mixing and dispensing cleaning solutions?

  • Are approved safety glasses required to be worn at all times when there is risk of eye injury (grinding, drilling, and chipping)?

  • Is eye protection worn throughout production, ag shops and whse areas?

  • Are protective gloves, wet suits, face shields, and foot protection, or other means provided against undiluted cleaning solutions (sanitation, clean up)?

  • Is all protective equipment maintained in a sanitary condition and ready for use?

  • Are steel-toed shoes being used by maintenance, forklift drivers, stackers, and other material handlers where exposure exists?

  • Are bump caps being worn throughout production and whse areas?

Respiratory Protection (1910.134)

  • Is annual training being conducted for the type of respirators being used?
    (In accordance with Company policy.)

  • Are users properly fitted with appropriate respirators?

  • Are monthly checks being conducted on respirators used for emergency purposes?

  • Are respirators stored in a clean/sanitary location?

  • Is an annual pulmonary function test being conducted for users of respirators?

  • Has IH study been performed for hazardous areas to determine exposures?

Hearing Conservation (1910.95)

  • Has a survey been done?

  • Are baseline and annual audiograms being conducted on employees exposed to 85DBA or more?

  • Are records kept for each employee and their results? (Review records)

  • Is the audiogram equipment calibrated annually?

  • Are periodic sound level checks being performed and documented?

  • Are standard threshold shifts (STS) documented and retested?

  • Are employees notified of audiogram results?

  • Do employees receive annual training on noise exposure, effects, precautions, and use of hearing protection (documented)?

  • Are areas of high noise levels (85dba) posted for required hearing protection?

  • Do employees have a variety types of hearing protection to choose from?

  • Are people wearing hearing protection where required?

Fall Protection (1910.66)

  • Has a workplace assessment been conducted to determine the need for fall protection?

  • Are fall protection systems used where required?

  • Are body harnesses/lanyards in good condition and inspected monthly?

  • Have employees who use fall protection adequately trained (training documented)?

Fire Protection (1910.157, .159)

  • Are fire extinguishers serviced annually and monthly inspections noted on the inspection tag?

  • Is fire extinguisher training provided to employees, who may be required to use extinguisher, on an annual basis (documented)?

  • Are extinguishers easily accessible and not obstructed?
    (ordinary combustible 75 feet, high combustible 50 feet)

  • Is sprinkler system (valves) locked in open position, secured, or provided with outside monitoring system for alarm and tampering purposes?

  • Do sprinkler heads have a minimum clearance of 18”?

Material Handling (1910.178)

  • Are forklift drivers trained initially and refresher training every 3 years minimum?

  • Are drivers utilizing seat belts?

  • Are containers/corrugate stored, stacked, blocked and limited in height so they are stable and secure?

  • Are vehicles shut off and brakes set prior to loading or unloading?

  • Are vehicles being loaded/unloaded by forklift choked or dock locks utilized?

  • Are forklifts maintained in safe operating condition?

  • Are daily forklift checks being conducted and documented?

  • Do electric forklift charging areas have acid neutralizers, immediately available fire protection, and adequate ventilation?

  • Are Propane tanks in good condition and stored properly

Hoist and Lifting Equipment (1910.179)

  • Are employees who utilize overhead hoist trained in the safe use and care of the equipment

  • Are monthly inspections of overhead hoist completed with documentation?

  • Are load ratings identified on hoist and jacks along with identified controls with safety clips on hooks?

  • Is rigging equipment (slings/chains/wire rope) free from damage and defects?

Tagout Procedures (1910.147)

  • Is a copy of the written Lockout/Tagout Policy on hand?

  • Have written procedures been established for locking out each piece and/or similar equipment and are updated when changes occur?

  • Review procedures: Is the date of last review of these procedures current?

  • Choose random procedure: go to machine and have authorized person perform LOTO procedure.

  • Is all machinery or equipment capable of movement, required to be de-energized or disengaged and blocked or tagged-out during cleaning, servicing, adjusting, or setting up operations, whenever required.

  • Does the Tagout procedure require that stored energy (mechanical, hydraulic, air, etc.) be released or blocked before equipment is locked-out for repairs/sanitation?

  • Is it required that only the employee(s) (or qualified service rep.) exposed to the hazard, place or remove their lockout?

  • Are locks and tags identified?

  • Is an annual documented audit performed to ensure Lockout/Tagout is being conducted as required?

  • Date of last review of equipment and employee

  • Have appropriate employees been adequately trained in lockout procedures?

  • What is disciplinary action policy for not following LOTO procedures?

  • Has the policy been strictly enforced? (documented action)

Machine Guarding and Safety (1910.219)

  • Are guards secured to equipment?

  • Have employee been trained in the prohibition of running unguarded equipment?

  • What is disciplinary action policy for removing guards or operating equipment without guards?

  • Has policy been strictly enforced (documented actions)

  • Are compressors and other pressure vessels equipped with pressure relief valves and gauges?

  • Are emergency stop buttons identified in red?

  • Are nip points, shear points, couplers, point of operation, gears and chains guarded?

  • Are all corners and edges of guards smooth and do not present a hazard itself?

Hand Tools and Equipment (1910.242, .243, .244)

  • Are all tools and equipment used by employees in the workplace in good condition?

  • Are broken or fractured handles on hammers and similar equipment replaced promptly?

  • Are guards utilized on powered hand grinders?

  • Are appropriate handles used on files and similar tools?

  • Are non-double insulated tools grounded?

  • Is compressed air for cleaning limited to 30 psi or equipped with safety nozzle?

  • Are load ratings identified on hoist and jacks along with safety clips on hooks?

  • Are Hoists and slings inspected?

  • Are arm saws arranged so that the cutting head returns back to the back of the table when released?

  • Is equipment anchored in place and made secure?

  • Is the grinder work rest adjusted to within 1/8-inch of the wheel and the tongue guard within ¼-inch and in compliance with other standard items for grinders?

Flammable and Combustible Materials (1910.253, .106)

  • Is there proper storage practices to minimize the risk of fire including spontaneous combustion including proper labeling?

  • Are “NO SMOKING” rules enforced in production and warehouse areas?

  • Are compressed gas cylinders secured in place?

  • Are oxygen cylinders stored away from items such as oil, grease, acetylene, and other fuel gas cylinders (20 feet or 5 feet non-combustible partition)?

  • Are flammable liquids and cylinders stored away from radiators, other sources of heat and exits?

  • Does oxygen/acetylene equipment have flashback arresters?

  • Are oxygen/acetylene equipment lines bled off and tanks closed when not in use?

  • Are hot work areas identified throughout the location and hot work permits utilized?

  • Review most recent permit for completeness/ accuracy

  • Are all bulk drums of flammable liquids grounded and bonded to containers during dispensing?

Hazardous Communication/Chemical Exposure (1910.1200)

  • Are employees aware of the potential hazards involving various chemicals stored or used in the workplace? (Review training signature sheet.)

  • Are all containers, such as drums and mixing tanks, etc., labeled as to their contents?

  • Have standard operating procedures been established and are they being followed when cleaning up chemical spills?

  • Are employees trained initially and annually in chemical hazards, symptoms, first-aid, precautions, labeling and other OSHA requirements?

  • Are Safety Data Sheets (SDS) readily available for each hazardous substance used? (Select a product and ask for SDS)

  • Is there a listing of hazardous substances used in the workplace?

  • Has the Process Safety Analysis been reviewed and updated every 5 years?

  • Was GHS training performed and documented?

  • Are SDS update according to GHS?

Electrical (1910.303, .304)

  • Are electrical appliances and equipment grounded?

  • Do extension cords being used have a grounding conductor and in good
    condition and used only as a temporary device?

  • Are all disconnecting switches and circuit breakers labeled to indicate their use?

  • Has facility been assessed for Arc Flash?

  • Are the requirements of the NFPA 70e being met (ppe, training labeling)?

  • Is there sufficient space (3 feet) to access power/disconnect panels?

Confined Space Entry

  • Are confined spaces identified and posted?

  • Are employees that are required to enter confined spaces and standby rescue people trained?

  • Are training records up to date/ complete?

  • Are entry permits being properly used?

  • Review most recent permit for accuracy and completeness

  • Are actual and potential hazards of each confined space identified along with written entry procedures?

  • Are protective measures identified and communicated to employees? (PPE, ventilation, etc.)

  • Are rescue procedures communicated with employees and outside services along with conducting non-entry mock rescue drills? (Fire & Rescue)

Air Monitoring (1910.1000)

  • Is personal and/or environmental monitoring being conducted for carbon monoxide and other known chemicals in the work place that employees are exposed to?

  • Are forklift emissions checked regularly for excessive CO discharge?

  • Are records kept on file of all air monitoring/testing/training?

General Work Environment (1910.141)

  • Are all work sites clean and orderly (good housekeeping)?

  • Are all spilled materials or liquids cleaned up immediately?

  • Are the floors of every workroom maintained in a clean and, so far as possible, a dry condition. Where wet processes are used, is drainage maintained, and false floors, platforms, mats, or other dry standing places provided where practicable?

  • Are hot pipes and equipment in pedestrian traffic areas insulated or isolated?

  • Is combustible scrap, debris, and waste stored safely and removed from the work site promptly?

  • Are all toilets and washing facilities clean and sanitary?

  • Are all work areas adequately illuminated?

  • Is work area monitored for heat or cold exposure?

  • Is heat exposure control plan warranted?.

  • Review plan employee training and monitoring systems

Misc/Other Recommendations

  • Are AED’s used and maintained in accordance with requirements?

  • Are AED’s checked monthly and documented?

  • Maintenance workers/welders training in Hex Chromium hazards (Stainless welding)?

  • Is there an established Yard Safety Policy in place/implemented that meets the company’s objectives (review plan).

Closing Conference

  • Select date

  • list All present and Titles

  • Were observations reviewed?

  • Is there a need for a follow up documentation

  • Is Employer Informed of Informal Conference

  • Are there any outstanding issues?

Employee Interviews

  • Employee interview may be held in private. Ask employee if representation is desired

  • Enter Interviewee information and answers to any questions

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