"Then they're going to want to go out into your facility, and they can talk to employees privately. And they're going to look for two things initially: if certain signage is up, warning of hazards, and if certain machines are guarded properly, equipment is being operated properly.
"Then they're going to talk to employees," he says. "They're going to pull one aside, and they'll talk to this person privately. They're going to ask this person what kind of safety orientation they got. What about job training? Let's say you had a mechanic changing tires—there's an OSHA regulation that requires them to operate this equipment a certain way—so if that person's doing that work, obviously they need to be trained to operate the equipment, so they'll ask about that."
Stromme explains that the OSHA inspector will ask that employee how often safety meetings are held, and whether they understand the hazards associated with their job. The inspector will ask if the employee understands what to do in an emergency, who to call, what number to call, and what to report.
"And then they're going to ask the employee if he or she feels his or her job tasks are safe," he says. "Or, do they feel apprehensive when they come to work every day?
"Somewhere in orientation training, you would want to communicate to your employees that if they see you walking around with someone and that person wants to talk to an employee, it's okay. You would tell them, 'Heaven forbid we have an OSHA inspection, but it could happen. And if an inspector wants to talk to you, he or she is going to identify himself or herself, show you an ID badge and ask you questions, and you should cooperate, answer truthfully, and tell him or her what they need to know.'
Stromme emphasizes the importance of having a safety officer on staff, who understands the hazards in the workplace and understands what needs to be done to protect employees.
"Now, does that mean a full-time safety person who, that's all they do? Maybe not," he says. "Maybe if you only have 15 employees, could you have one of them do that job full-time? Probably not. But it could be anyone who is knowledgeable and willing to take the responsibility in training, and is also knowledgeable about the hazards. It's very important, because if an inspector comes on-site, he needs to have a point person to talk to."
Just as important, according to Stromme, is your record keeping. "If you have 11 or more employees, that's the threshold where you end up having a certain number of additional obligations: you've got to fill out the OSHA 300A and 301 record keeping logs, and you have to post those for a certain period of time," he explains. "Less than 11, you don't have to do quite as much, but if you have even one employee, in a facility that is doing maintenance, there are probably going to be a lot of chemicals. A hazard communication program is a requirement.
"You're going to have equipment that you may have to lock out or tag out," he continues. "You have to have a written program for that. And you have to comply with all the other standards that protect your employees against hazards.
"Flammable liquids are another area," Stromme adds. "You have to have an emergency action plan if you have more than 11 employees. What if there's a fire emergency? There's just a myriad number of regulations that you may have to comply with. The person that's tasked with that responsibility has to understand that there's a hazard, and what he or she needs to do to be in compliance with OSHA regulations. It can be a very daunting task.
"Safety has to start at the top," he concludes. "Be it the company owner, or the person put in charge of a facility, it has to start at the top. If it doesn't start there, you'll never get buy-in from any of the managers. If management doesn't express an interest in safety—or, worse, they cut corners and needlessly put workers at risk—it's never going to get off the ground, and you're going to have accidents, and you're going to have OSHA knocking at your door."