So OSHA shows up at your job site and sees one of your employees working from a ladder from the side and asks you, "Did that person attend ladder safety training?" What is your initial response? (Hint....how you respond to their very first question will determine how far the inspector digs to find violations of the standards)
Keep in mind that the OSHA Inspector has probably been parked across the street watching your workers for the past hour. That is how they decide what to go ask you about. So, if all of your employees have been misusing ladders for the past hour, you will be hard pressed to say they have all been trained. However, if this is an isolated incident, how you answer the inspectors question will make a big difference in the rest of your inspection.
If your job-site is a construction site. You may be able to "limit the scope of the inspection" with your very first answer. If your answer goes something like this, you have a good chance of limiting the scope. "Yes officer, all of our employees who use ladders have had training in the proper use. I am as shocked as you are to see that he/she is using the ladder improperly. We have a comprehensive safety program that includes training on all the construction hazards. Let me just check for you when the ladder training was conducted.......If you are using the "compliance ready safety management software" then it will be easy to pull up the date that training was provided right on your phone. That kind of a response will put the inspector "off guard" and he will be impressed that (1) you knew ladder training was required, (2) you had conducted ladder training, (3) that you are able to provide him the date the last training was held, (4) these factors support your statement that you have a "comprehensive safety program" and should lead to the inspection being limited to "the focus four hazards". That is good news for you!
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Author: Deborah Grow, Safety Compliance Specialist
Private Safety Consultant, Sales-Marketing Director Damon Fall Protection and Coordinator EHS Network ~ Kansas.
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