HOW TO HANDLE AND OSHA INSPECTION

PURPOSE

To provide procedures that must be followed by all Nichols Construction Team employees when an OSHA inspection occurs on site(s)

1. Pre-Inspection Meeting and walk through:

a. When an OSHA inspector arrives, he/she should be met at the on-site office by the appropriate Company representative(s) and escorted to a conference room for a pre- inspection meeting. At least two Company representatives should be in attendance at the pre-inspection meeting. One should be (if possible) the Company’s Safety Director.

b. The Company representative(s) should request and the credentials of the inspector. If available, request a photo-ID card that indicated the name of the inspector and the agency that he/she represents. If the inspector cannot provide credentials, the visit should not proceed until the credentials are provided.

c. If the inspection is the result of an official complaint, request a copy of the complaint before commencing with the inspection.

d. Identify a suitable location away from the conference area and immediately notify the senior manager, (Sr. VP, general superintendent or Project Executive) as well as the Safety Director, (Mary Kay Bly) and inform them of the reason of the inspection. OSHA will typically give 20 minutes for the manager and/or safety director to arrive and join the meeting.

e. If the inspection is the result of a Dodge report and/or a scheduled inspection the same applies as in letter (d).

f. The inspector at this time will ask for information such as; the manager (superintendent), for the site, the role of the manager’s Company (G.C./C.M etc.) and further Company information. The inspector will also ask for the Company names of all trades on site.

g. Determine the exact area(s) of the site the inspector wishes to visit and the records they need to review. Any documents requested to be reviewed by the inspector should be taken to the conference room where the records review should take place.

h. If the inspector intends to use photographic or videotape equipment, they should be advised of our intention to use similar equipment.

i. The inspector is responsible for providing and utilizing personal protective equipment (PPE) as required by the Company. Caution them on any hazards that could be encountered during the inspection (e.g., moving cranes, hazardous chemicals), and take any other precautions deemed necessary.

j. The senior manager, safety director and/or Superintendent on site will walk with the inspector. If a question is asked, a short concise answer is sufficient. If the inspector takes a photo and/or video the senior manager, safety director and/or superintendent will do the same.

k. If the inspector finds any issue, those issue must be corrected immediately and a photo must be taken for proof of correction.

2. Post-Inspection/Closing Conference:

a. Following the inspection, the inspector will ask for any trade with an issue(s) to attend the closing conference meeting.

b. The inspector will indicate his/her findings to the trade(s).

c. The inspector will indicate at this time whether he finds the G.C/C.M. at fault for any issue(s).

If no closing conference was conducted, it is left opened for future visits.

The bottom line;

Be polite, show the inspector only the area(s) in question, the less talking the better and take photos as they do.

This information should be passed down to all Watchdog employees as to prevent any misunderstandings and to allow the manager to do his/her job.

A detailed report must be completed for record keeping.