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Prepare a response team, documents and split samples for OSHA inspections, trainer says

October 06, 2025 | Utah Government Trust, Utah Government Divisions, Utah Legislative Branch, Utah


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Prepare a response team, documents and split samples for OSHA inspections, trainer says
A presenter in a workplace-safety training said agencies should expect unannounced inspections from federal OSHA or the state-run Utah Occupational Safety and Health program and be prepared with a response team, documents and on-site sampling procedures.

The presenter, a staff member leading the training, said agencies should build a team with 24-hour contact information and assign duties for obtaining documents, escorting inspectors and taking notes. “OSHA inspector's here. You better get here now,” the presenter quoted an example of how an inspection can be announced, adding that inspections are often unexpected and “can really scare you to death.”

The training laid out why inspections happen and what public employers in Utah should expect. The presenter described four common triggers: programmed inspections, complaints, accident responses and referrals from other agencies. He also emphasized a state local emphasis program that targets public-sector employers, noting that municipalities with populations greater than 1,000, special service districts and all police, fire and correctional facilities are in the pool for focused inspections.

The presenter said agencies must report serious injuries promptly and cited an eight‑hour notification requirement for serious accidents. He also warned that Utah law prevents the Labor Commission from assessing monetary penalties against state agencies and political subdivisions for OSHA violations but said citations still carry consequences, including the risk of repeat or willful violations that can escalate to criminal charges. The presenter noted that the state legislature recently adjusted the standard for willful or criminal violations.

On documents the presenter recommended having binders organized by subject (OSHA 300 logs, training records, safety policies, sampling/exposure data and proof of reported injuries) so requested materials can be produced quickly. He advised making and providing copies rather than original records, and consulting counsel before producing documents whose access is uncertain. “Do not let the inspector take the originals,” the presenter said.

The trainer described on‑site procedures: ask inspectors to present identification and make a photocopy; hold an opening conference to define scope; accompany inspectors during walk-throughs (except for private interviews with non‑supervisory employees); and request a closing conference to clarify observed concerns. He advised restricting the inspection to the stated scope, limiting routes that expose inspectors to unrelated problem areas, and asking for time if many copies are requested.

The presenter recommended a “go bag” with a camera or phone to take photos and video to mirror inspector recordings, a tape measure, flashlight and sampling equipment where applicable. If inspectors take environmental or noise samples, he advised taking split samples at the same time and sending them to an independent lab to corroborate results. He also recommended documenting start and end times, photographing any items the inspector photographs, and taking detailed notes during the inspection.

On working with inspectors the presenter recommended courtesy and truthfulness but cautioned against unsolicited explanations. “Yes and no are perfectly appropriate answers to many questions,” he said, and suggested saying “I don't know” or “I will get back to you” when appropriate. He warned against retaliation against employees who speak to OSHA, reminding employers that employees may request inspections anonymously and are protected from retaliation.

After an inspection, the presenter advised preparing a factual internal memo to upper management summarizing observations and next steps, tracking corrective actions to completion before citations arrive, and using an informal conference or notice of contest if citations are issued. He noted employers must post a notice of alleged violation near the location for three days and that agencies can request an informal conference with the state OSHA office (for example, in Salt Lake City) to contest findings.

The session closed with a reminder of common citation areas and the primary objective: maintain a safety program so employees go home safely. The moderator invited questions and offered follow-up assistance from the presenters and their colleagues.

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