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3 Key Stages of an OSHA Inspection: What to Expect

3 Key Stages of an OSHA Inspection: What to Expect 

OSHA compliance officers conduct workplace inspections without advance notice. A compliance officer can show up at your facility without warning, and the OSHA inspection process that follows is one every safety professional should understand before it happens. The good news is that OSHA follows a predictable, three-stage structure: the opening conference, the walkaround inspection, and the closing conference. Knowing what to expect at each stage helps you respond effectively, protect your employees' rights, and demonstrate the kind of good faith that can affect penalty reductions and case handling.

Stage 1: Opening Conference

The inspection begins when the OSHA compliance officer arrives and presents credentials, which include a photograph and serial number. You have the right to verify these credentials before granting entry. Employers also have the right to require the compliance officer to obtain an inspection warrant before entering the worksite, though in practice most employers allow entry voluntarily since the inspection will likely proceed either way.

During the opening conference, the compliance officer explains why your workplace was selected for inspection and outlines the scope of the visit. OSHA prioritizes its inspection resources based on the following criteria:

  • Imminent danger situations where hazards could cause death or serious physical harm

  • Severe injuries and illnesses, including all work-related fatalities (reported within 8 hours) and all inpatient hospitalizations, amputations, or losses of an eye (reported within 24 hours)

  • Worker complaints alleging hazards or violations

  • Referrals from other federal, state, or local agencies, individuals, organizations, or the media

  • Targeted inspections aimed at specific high-hazard industries or workplaces with elevated injury and illness rates

  • Follow-up inspections to verify that previously cited hazards have been corrected

The employer then selects a representative to accompany the compliance officer during the inspection. Choose someone who knows your operations, can take detailed notes, and has the authority to answer questions or authorize immediate corrections. An authorized employee representative also has the right to accompany the inspector during the walkaround.

Employee Representative Rights

Under the walkaround representative rule finalized in 2024, employees may designate a representative, including in some cases a non-employee, to participate in the walkaround inspection. For a non-employee to accompany the inspection, OSHA applies a standard based on whether the person is reasonably necessary to an effective and thorough inspection. The compliance officer will also consult privately with a reasonable number of employees during the visit. These conversations are confidential, and employees are protected from retaliation for participating.

How a Regulatory Event Manager Software Module Can Help

The Regulatory Event Manager module from EHSSoftware.io helps safety teams stay organized across every stage of a regulatory event like an OSHA inspection.

The regulatory event manager centralizes the deadlines, documentation, findings and follow-up tasks that can quickly become difficult to manage in email and spreadsheets. During and after an inspection, it gives your team one place to log the event, assign owners, document finding, manage corrective actions, monitor abatement deadlines, and maintain the evidence needed for verification and response. That visibility makes it easier to protect deadlines, show good faith, and keep inspection-related work moving from event to closure.

Stage 2: The Walkaround Inspection

During the walkaround, the compliance officer physically inspects workplace conditions, equipment, and work practices. The compliance officer, accompanied by the employer and employee representatives, walks through the portions of the workplace covered by the inspection. The officer is looking for hazards that could cause injury or illness, but the scope can expand beyond the original trigger if additional hazards are observed.

Inspectors examine physical conditions, work practices, and equipment. They also review your OSHA 300 Log, 300A Summary, and 301 Incident Report forms, along with written safety programs, training records, and Safety Data Sheets (SDSs). The OSHA poster informing employees of their rights must be displayed and may be checked during the visit.

Employee Interviews

The compliance officer may conduct informal interviews with employees during the walkaround and may also request private, formal interviews. Employer or employee representatives are generally not present during private interviews unless the employee requests it. Employees have the right to speak freely about workplace conditions without fear of retaliation. These conversations help the inspector understand day-to-day operations and identify hazards that may not be visible during a walkthrough.

As the employer representative, your role during the walkaround is to observe, take notes, and photograph anything the compliance officer photographs or samples. If the officer identifies trade secrets during the inspection, OSHA is required to keep that information confidential. If you see a hazard that can be corrected immediately, do so. While the violation may still be cited, prompt correction demonstrates good faith and can reduce proposed penalties.

Stage 3: Closing Conference

After completing the walkaround, the compliance officer holds a closing conference with the employer and employee representatives. The officer discusses the findings, identifies potential violations, and explains the possible courses of action available to the employer. The compliance officer may discuss apparent violations during the closing conference, but citations and penalties are issued later by OSHA and are not finalized at the conference.

If OSHA determines that violations occurred, the agency may issue citations and proposed penalties. OSHA must issue citations within six months of the violation's occurrence. Violations fall into the following categories:

  • Willful: the employer knowingly committed or showed plain indifference to a violation

  • Serious: the hazard could cause death or serious physical harm, and the employer knew or should have known about it

  • Other-than-serious: the violation has a direct relationship to safety and health but would not likely cause death or serious physical harm

  • Repeat: the employer was previously cited for the same or a substantially similar condition

  • Failure to abate: a previously cited hazard has not been corrected by the original abatement deadline

  • De minimis: a technical violation with no direct or immediate relationship to safety or health (no penalty assessed)

Maximum penalty amounts are adjusted annually for inflation. For penalties proposed after January 15, 2025, the maximum is $16,550 per violation for serious, other-than-serious, and posting requirement violations. Willful or repeated violations carry a maximum of $165,514 per violation. Failure to abate penalties can reach $16,550 per day beyond the abatement deadline. OSHA considers the employer's size, gravity of the violation, good faith, and history of previous violations when calculating proposed penalties.

The compliance officer will also inform you of your right to contest. If you disagree with the citations, penalties, or abatement dates, you have 15 working days after receiving the citation to submit written notice to the OSHA Area Director. If you do not contest within that period, the citation becomes a final order of the Occupational Safety and Health Review Commission (OSHRC).

After the Inspection: Citations, Abatement, and Next Steps

Once you receive a citation, you must post a copy at or near the location where each violation occurred. The citation must remain posted for 3 working days (excluding weekends and federal holidays) or until the hazard is abated, whichever is longer. This posting requirement ensures affected employees are aware of the findings.

You are required to correct cited hazards by the abatement date listed on the citation and submit documentation confirming that corrections were made. Abatement documentation typically includes written verification, photographs, receipts for equipment purchases or repairs, and updated training records. If you need additional time, you may file a Petition for Modification of Abatement (PMA) with the Area Director before the abatement deadline.

Before deciding whether to contest, consider requesting an informal conference with the OSHA Area Director. An informal conference is not required, but it gives you the opportunity to discuss the citations, present evidence, negotiate penalties, and potentially reach a settlement agreement. Keep in mind that the 15 working day contest period continues to run during an informal conference. If settlement discussions do not resolve the matter, you must still file a written notice of contest before the deadline expires.

How to Prepare for an OSHA Inspection

Effective OSHA inspection preparation requires ongoing compliance activities, not last-minute action. The following steps keep your facility inspection-ready at all times:

Designate an inspection coordinator. Identify the person (or people, across shifts) who will serve as the company representative during an inspection. Make sure they know the process and have authority to make decisions.

Keep OSHA records current. Your 300 Log, 300A Summary, and 301 forms should be complete and accessible. Inspectors will ask for these. Recordkeeping requirements across multiple sites add complexity, so make sure each location maintains its own records.

Maintain written safety programs. Hazard communication plans, lockout/tagout procedures, emergency action plans, and any other required written programs should be up to date and readily available.

Train employees. Workers should know their rights during an inspection, including the right to speak privately with the compliance officer and the right to designate a representative.

Conduct internal audits. Regular self-inspections help you identify and correct hazards before OSHA does. Document these audits and the corrective actions you take.

A Regulatory Event Manager can help track compliance deadlines, manage inspection findings, and document corrective actions in one place, making it easier to stay organized before, during, and after an OSHA visit.

Conclusion

An OSHA inspection does not have to be a crisis. The process follows a clear structure, and your response at each stage shapes the outcome. Preparation, cooperation, and prompt correction of hazards demonstrate the kind of good faith that OSHA considers when determining penalties. Stay inspection ready, know your rights, and treat every inspection as an opportunity to strengthen your safety program.

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