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The Importance of Documentation
By: Michael Messer, Safety Consultant

There is a common saying that if you did not document, it did not happen. Documentation takes time, but is a necessity and will save you valuable time and money in the long run.

There are several OSHA standards and regulations that require documentation that you may not be aware of. There are also several OSHA standards and regulations that require visual inspection. If visual inspections are required it is always recommended to take it a step further and document to truly protect your company from OSHA fines and protect employees from preventable incidents from happening. In the event you receive OSHA citations, you want to be prepared and one way in doing so is having documentation to aid in abatement.

For starters, document safety trainings. One common citation is that an employer did not have each employee, who was performing the work trained by a person qualified in the subject matter to recognize the hazards and understand the procedures to control or minimize those hazards. Employer safety trainings records are among the first things that an inspector wants to see when an OSHA compliance audit is performed at your company. Saying that your employees get safety training by doing the job or that your supervisor trains employees under their control, how to do the job safely will not be sufficient. Training records need to have the following information, at a minimum: 

  • Date of the meeting
  • Topics discussed
  • Names of all attendees printed and signed. 

Is your company conducting safety and healthy inspections, and if so, are those being documented? If the training is not properly documented, OSHA likely will not see that training as valid. Frequent and regular inspections of a job site, materials, and equipment are required to be made by a competent person. It is recommended that, at a minimum, weekly safety and health inspections be performed. Take it a step further and have notes in a daily log of hazards being found and corrected, or even positive findings out on the job site. 

When it comes to conducting inspections for equipment, such as aerial lifts, forklifts, etc., most equipment requires visual inspection performed prior to use. Having an inspection sheet given to an employee will help provide them with a list of parts to inspect that may otherwise get missed. Even though you say inspections are taking place, they will fall on deaf ears without proof. For example, suppose a part on an aerial lift is found to be damaged. In that case, you can get cited on for components not being inspected for visible defects by a competent person, before each work shift, and after any occurrence, which could affect a scaffold’s integrity. 

More OSHA standards require proper documentation; rigging equipment, personal fall arrest equipment, work-related injuries, illness, etc. If you would like additional information, or would like assistance with documentation/record keeping, reach out to Michael Messer today! 
U.S. Department of Labor's OSHA Announces $3,148,452 in Coronavirus Violations
WASHINGTON, DC – Since the start of the coronavirus pandemic through Nov. 12, 2020, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has issued 232 citations arising from inspections for violations relating to coronavirus, resulting in proposed penalties totaling $3,148,452.
OSHA inspections have resulted in the agency citing employers for violations, including failures to:

OSHA has already announced citations relating to the coronavirus arising out of 203 inspections, which can be found at dol.gov/newsroom. In addition to those inspections, there have been 29 inspections that have resulted in coronavirus-related citations totaling $296,919 from OSHA relating to one or more of the above violations from Nov. 6 to Nov. 12, 2020. OSHA provides more information about individual citations at its Establishment Search website, which it updates periodically.