📋 OSHA Inspection Response Playbook
When OSHA arrives, preparation and protocol matter. Know your rights, assign roles, and document everything. Proper response protects your company and can influence the outcome of citations.
Why This Matters
| Without a Plan | With a Plan |
|---|---|
| Panic, inconsistent responses | Calm, coordinated response |
| Missed documentation | Everything photographed and noted |
| Volunteer information that expands scope | Scope limited to inspection type |
| No legal support ready | Attorney notified immediately |
| Hazards unfixed after inspection | Immediate correction shows good faith |
Be Prepared
You may never have an OSHA inspection — but if you do, having this playbook ready and your team trained will make all the difference. Review it annually with leadership and site management.
Types of OSHA Inspections
| Type | Trigger | Typical Scope |
|---|---|---|
| Imminent danger | Condition that could cause death/serious harm | Immediate correction; possible shutdown |
| Fatality/catastrophe | Death or 3+ hospitalizations | Full site investigation |
| Complaint | Worker or public complaint | Scope limited to complaint (unless expansion justified) |
| Programmed | Random or industry-targeted | May cover entire site or focus area |
| Referral | From another agency (EPA, etc.) | Depends on referral |
| Follow-up | Verifying abatement of prior citations | Prior violation areas |
Your Rights
| Right | Detail |
|---|---|
| Accompany the inspector | You or a designated representative may accompany the inspector throughout the walkaround |
| Take photos | Take your own photos of everything the inspector photographs |
| Take notes | Document what the inspector looks at, asks, and comments on |
| Limit scope (complaint) | For complaint inspections, scope is limited to the complaint unless inspector sees other violations "in plain view" |
| Warrant | Inspector may have a warrant; comply but you may contact legal counsel |
Roles and Responsibilities
| Role | Responsibilities |
|---|---|
| Greeter | Verify credentials, contact management, do not delay entry |
| Accompany | Designated person (superintendent, safety director) accompanies inspector at all times |
| Document | Take photos, notes, record everything inspector photographs and asks |
| Legal contact | Notify attorney immediately (fatality, serious injury, or per company policy) |
Phase 1: Arrival
- Verify credentials — Request OSHA credentials (photo ID, jurisdiction). Verify they're from federal OSHA or state plan.
- Contact management — Notify superintendent, safety director, and (if policy) company leadership immediately.
- Notify legal — For fatality, catastrophe, or if company policy requires — call attorney before opening conference.
- Do not obstruct — Refusing entry (without a warrant) can result in separate violations. Allow entry while you make calls.
Phase 2: Opening Conference
Understand before the walkaround begins:
| Question | Why It Matters |
|---|---|
| What type of inspection is this? | Determines scope and focus |
| What is the reason for the inspection? | Complaint — get copy; programmed — understand focus |
| What areas will be inspected? | Plan who accompanies and what to document |
| How long is this expected to take? | Plan staffing |
Do not volunteer information beyond what is asked. Do not offer to show other areas. Answer questions factually; do not speculate.
Phase 3: Walkaround
| Action | Detail |
|---|---|
| Accompany | Designated person stays with inspector at all times |
| Document | Photograph everything the inspector photographs — same angles |
| Notes | Record: where they went, what they looked at, questions they asked, comments made |
| Employee interviews | If inspector requests to interview workers, see Phase 4 |
| Stay calm | Do not argue, obstruct, or become defensive |
If the inspector finds something: Do not admit violations. Note it. Correct it as soon as practicable after the inspection.
Phase 4: Employee Interviews
| Right | Detail |
|---|---|
| Workers | Workers have the right to speak to OSHA privately; you cannot prevent it |
| Company | You may have a representative present if the worker agrees (OSHA policy varies) |
| Preparedness | Train workers: tell the truth; they may decline to answer if they prefer |
Do not: Coach workers, threaten retribution, or discourage them from speaking. Retaliation is illegal and can lead to whistleblower claims.
Phase 5: Closing Conference
At the end of the inspection:
| Action | Detail |
|---|---|
| Ask questions | What violations are they considering? What is the classification (serious, willful, etc.)? |
| Timeline | When can you expect citations? Normal process: weeks to months |
| Abatement | What will they expect for correction? |
| Take notes | Document everything said in the closing conference |
You may receive: Informal list of hazards. Even if citations aren't issued, correct hazards immediately.
Phase 6: Post-Inspection
- Compile documentation — All photos, notes, inspection type, inspector name, date. Create a summary.
- Consult legal — Share documentation. Legal can advise on citation response, settlement, or contest.
- Correct hazards — Address any hazards identified — immediately. Document corrections with photos.
- Prepare for citations — If citations are issued, you have 15 working days to contest. Legal will guide.
What NOT to Do
| Don't | Why |
|---|---|
| Lie | Criminal liability; destroys credibility |
| Obstruct | Separate violation; makes everything worse |
| Volunteer information | Can expand scope of inspection |
| Argue with inspector | Stay professional; note concerns for legal |
| Admit violations | Let the process play out; correction shows good faith without admission |
| Destroy or alter evidence | Serious legal consequences |
BLDR Pro During Inspection
Use BLDR Pro to document in real time during the OSHA walkaround. Photo-tag every location the inspector photographs — take your own shots of the same angles. Add notes for questions asked and comments made. Create an inspection log with timestamps. When citations arrive or legal needs a timeline, your documentation is ready.
Metrics: Preparedness Focus
This playbook is about preparedness. Track:
| Metric | Purpose |
|---|---|
| Playbook review completed | Annual with superintendent and safety director |
| Designated roles assigned | Who greets, accompanies, documents |
| Legal contact info current | Attorney on speed dial |
| Credential verification practiced | Know how to verify OSHA credentials |
Common Mistakes
| Mistake | Problem | Fix |
|---|---|---|
| Delaying entry | Can be cited for obstruction | Verify credentials quickly; contact management while escorting |
| No one accompanies | Miss what inspector sees and says | Designate accompany person before inspection |
| No documentation | No record for defense or abatement | Photos and notes of everything |
| Arguing | Antagonizes inspector; no benefit | Stay professional; note for legal |
| Not correcting hazards | Shows indifference; worse penalties | Correct immediately; document |
Troubleshooting
"Inspector wants to see something we're not ready to show"
- You may ask the reason. For complaint inspections, scope is limited. For programmed, they have broad access. Do not obstruct; accompany and document.
"Inspector is taking photos of something we think is compliant"
- Do not argue. Take your own photos. Note the context. Your documentation and legal counsel can address it during the citation process if needed.
"A worker says something incorrect to OSHA"
- Workers have the right to speak. You cannot retaliate. If the statement is factually wrong, your documentation and legal response can address it. Do not confront the worker.
"We got citations we disagree with"
- You have 15 working days to contest. Involve legal immediately. Correction of hazards does not mean you accept the citation — you can correct and still contest.
Related Resources
| Resource | Link |
|---|---|
| OSHA Inspection Checklist | OSHA Inspection Checklist |
| Incident Reporting Playbook | Incident Reporting |
| Site Safety Inspection Playbook | Site Safety Inspections |
| OSHA Penalties Reference | OSHA Penalties |