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Safety Watch permission to expand the inspection. Keep in mind that compliance officers are trained to keep all observed trade secrets confidential. Te compliance ofcer may also consult with your employees during the inspection tour. He or she may stop and question employees in private about safety and health conditions and practices at their workstations. Please remember that you are prohibited by law to discriminate against employees who are exercising their safety and health rights. Something else to consider: OSHA places special importance on posting and recordkeeping requirements. Te compliance ofcer will inspect records of deaths, injuries, and illnesses that you are required to keep on your OSHA 300 log. He or she will also check to see that a copy of the previous year's OSHA 300A Form (Annual Summary) is signed and posted as required and that the OSHA workplace poster, which explains employees' safety and health rights, is prominently displayed. Further, if records of employee exposure to toxic substances and harmful physical agents are required, the compliance ofcer will examine them for compliance with the recordkeeping requirements. Te compliance ofcer will also request a copy of the Hazard Communication Program. Under OSHA's Hazard Communication Standard, employers must establish a written, comprehensive communication program that includes provisions for container labeling, material safety data sheets, and an employee training program. Te program must contain a list of the hazardous chemicals in each work area and the means the employer will use to inform employees of the hazards associated with these chemicals. Te recently promulgated Hazard Communication changes, as part of the Globally Harmonized Standard, and the implementation schedule must also be included in your program. During the course of the inspection, the compliance ofcer will point out any unsafe or unhealthful working conditions observed. At the same time, he or she will discuss possible corrective action if you request it. It is strongly recommended that you always request and document the compliance ofcer's opinion on an appropriate corrective action. Some apparent violations detected by the compliance ofcer can be corrected immediately. If you correct them on the spot, the compliance ofcer records the corrections to help in judging your good faith in compliance. Although corrected, the apparent violations may still serve as the basis for a citation and, if appropriate, a notice of proposed penalty. However, OSHA may reduce the penalties for some types of violations if they are corrected immediately. The Closing Conference At the conclusion of the inspection, the compliance ofcer will conduct a closing conference with you, your employees involved in the inspection, and/or the employees' representative. Under OSHA's Hazard Communication Standard, employers must establish a written, comprehensive communication program that includes provisions for container labeling, material safety data sheets, and an employee training program. 42 JANUARY 2014 COATINGSPROMAG.COM Te compliance ofcer will give all other parties involved a copy of Employer Rights and Responsibilities Following an OSHA Inspection for your review and discussion. At the closing conference, the compliance officer will discuss all unsafe or unhealthful conditions that he or she observed during the inspection, indicate all apparent violations for which he or she may issue, or recommend a citation and a proposed penalty. The compliance officer will not indicate any specific proposed penalties but will inform you of your appeal rights. This process actually takes place at the area office and always includes the area director or the assistant director. After the closing conference, things will generally return to normal in the workplace while you wait for the area ofce to determine if any safety citations, and proposed penalties, will be issued. While the inspection can take a couple of hours or no longer than a shift from opening to closing conference, the process of waiting for feedback can take 45–60 days, and you will always receive the results via certifed mail. Once the inspection is complete, there are several possible outcomes, but the overall goal is to create a safe and healthy workplace for your employees, contractors, and visitors. CP Jack Fearing, CPEA, is the president of Fearing International Group, a global occupational safety and health consulting firm. He has more than 30 years of extensive experience in occupational safety and health compliance in the manufacturing, chemical, pharmaceutical, and defense industries. His most recent position was director of global safety and health at DynCorp International. He is a retired U.S. Army Lt. Colonel and was a helicopter pilot and aviation safety officer. He is a graduate of the University of Massachusetts and Boston University and is an authorized OSHA general industry 10/30 hour trainer. For more information, contact: Jack Fearing, (908) 303-8359, jjfearing@gmail.com