OSHA Inspection Prep Guide: Manufacturing Facilities

1. Recordkeeping and incident records — 29 CFR Part 1904

Start with the recordkeeping coordinator and make the site’s injury-and-illness records easy to retrieve. The inspector may sample recent incidents, compare the log to first-aid and workers’ compensation information, and ask how the site decides whether a case is recordable.

• ✓ Records and floor evidence. Assemble the OSHA 300 Log, 300A Summary, 301 Incident Reports or equivalent forms, supporting incident files, required posting or submission evidence, and the retained record set. Reconcile incident dates, restricted work, days away, medical treatment, and case descriptions before the inspection.
• ✓ Inspector questions. Which cases were recordable, who made that determination, where is the supporting documentation, and can the site produce the required records for the applicable retention period?
• ✓ Readiness owner. The OSHA recordkeeper or HR owner leads the records; the EHS manager validates the classification logic and makes sure operations leaders know where the source evidence lives.
• ✓ Common citation trigger. Missing or inconsistent entries, an incomplete incident record, a required summary that was not posted when applicable, or records that cannot be produced because ownership is split across EHS, HR, and workers’ compensation files.

2. Hazard communication — §1910.1200

HazCom readiness is visible in the chemical crib, production areas, maintenance shop, and employee interviews. The written program, chemical inventory, labels, safety data sheets, and training need to describe the same workplace.

• ✓ Records and floor evidence. Centralize the written hazard communication program, current chemical inventory, SDS access path, non-routine-task and multi-employer communication methods, label examples, and employee training records. Walk the floor to confirm shipped containers and workplace containers are labeled as required.
• ✓ Inspector questions. What chemicals are used here, where is the SDS for this product, what do the label pictograms and signal words mean, and what precautions apply to a spill, line break, or other non-routine task?
• ✓ Readiness owner. The EHS or chemical-program owner maintains the program and SDS access; area supervisors own container checks and ensure employees can access information during their work shift.
• ✓ Common citation trigger. An unlabeled secondary container, an SDS that is not readily accessible, a written program that omits an actual chemical or task, or employees who cannot explain the hazards and protective measures for the work they perform.

3. Machine guarding — §1910.212 + applicable machine-specific standards

Do not audit guarding from the maintenance office. Pick representative machines and inspect the point of operation, ingoing nip points, rotating parts, and access paths exactly as an operator or mechanic encounters them. Then confirm whether a machine-specific standard also applies.

• ✓ Records and floor evidence. Assemble the machine inventory, guarding assessments, manufacturer or engineering specifications, inspection and repair records, and any interlock or guard-change approvals. On the floor, verify guards are present, secured, effective, and not defeated or left removed after service.
• ✓ Inspector questions. What prevents access to the point of operation, how is the guard inspected after maintenance, who may remove it, and which machine-specific standard or manufacturer requirement governs this equipment?
• ✓ Readiness owner. Maintenance and engineering own the guarding design and repair evidence; production supervisors own daily condition checks and escalation when a guard is damaged or bypassed.
• ✓ Common citation trigger. An exposed point of operation, unguarded nip or rotating part, a gap that permits access, a missing or improvised guard, or a bypassed safeguarding device that employees have learned to treat as normal.

4. Lockout/tagout — §1910.147

LOTO is the place where paperwork and behavior have to match. Select a machine, pull its written energy-control procedure, and watch the shutdown, isolation, stored-energy control, verification, and return-to-service sequence. A generic procedure cannot explain a machine-specific isolation point.

• ✓ Records and floor evidence. Prepare machine-specific procedures, energy-source and isolation-point maps, authorized and affected employee training, annual periodic-inspection records, group-lockout and shift-change methods, and retraining or corrective-action evidence. On the floor, verify locks, tags, blocking, and the documented verification step are usable.
• ✓ Inspector questions. Show the procedure for this asset; who is authorized; how is each energy source isolated and verified; how are stored or residual energy and group work controlled; and what happens during a shift change or procedure change?
• ✓ Readiness owner. The LOTO program owner or maintenance manager owns procedures and inspection records; supervisors own field execution and ensure only trained authorized employees perform the work.
• ✓ Common citation trigger. A generic or incomplete procedure, an overdue periodic inspection, missing training or retraining, no documented verification, uncontrolled shift or group work, or an employee exposed while another person assumes the lockout is sufficient.

5. PPE hazard assessment, selection, and training — §1910.132 + applicable PPE standards

PPE readiness starts with the hazard assessment, not the cabinet. The assessment, selected equipment, task instructions, and employee behavior should line up for each job or area, with additional requirements addressed where respirators, hearing protection, eye and face protection, head protection, foot protection, or other PPE standards apply.

• ✓ Records and floor evidence. Centralize written hazard assessments and their certifications, PPE selection matrices, training records, inspection or replacement criteria, and task-specific evaluations. On the floor, check condition, fit, compatibility, storage, and actual use for the hazards identified.
• ✓ Inspector questions. What hazard does this PPE control, how was it selected, when is it required, what are its limitations, how is it inspected and maintained, and can the employee demonstrate the required use?
• ✓ Readiness owner. EHS owns the hazard assessment and selection criteria; area supervisors own task-level enforcement, replacement escalation, and verifying that training remains effective.
• ✓ Common citation trigger. No documented assessment or certification, PPE that does not match the task hazard, damaged or incompatible equipment, employees who were not trained on limitations and care, or a task-specific PPE standard that was never folded into the program.

30–14 days out: assign ownership and build the evidence index

• ✓ Name an inspection lead, primary escort, backup escort, records coordinator, and contacts for maintenance, production, HR, and chemical management.
• ✓ Create one index linking the current procedures, logs, SDS library, training evidence, hazard assessments, machine inventory, corrective actions, and responsible owner for each item.
• ✓ Confirm that the records index points to the actual controlled copy, not an abandoned shared-drive folder or a draft procedure.

7 days out: walk the floor and interview the people doing the work

• ✓ Walk every production area, maintenance shop, chemical storage area, and representative shift for visible hazards, labeling, guarding, LOTO condition, PPE use, housekeeping, and access to emergency information.
• ✓ Interview supervisors and authorized employees using the same questions an inspector may ask: where is the procedure, what changed, how do you verify, and what do you do when the control is missing?
• ✓ Sample documents against the floor: if a procedure names one asset, one chemical, or one PPE task, confirm the named control exists where the employee works.

72–24 hours out: correct urgent deficiencies and rehearse retrieval

• ✓ Correct imminent or obvious hazards through the site’s normal corrective-action process, assign owners and dates, and preserve an accurate record of what was found and corrected. Never backdate, delete, hide, or alter records to make the site look compliant.
• ✓ Rehearse retrieving one complete evidence packet for each of the five inspection areas, including the source document, current revision, training or inspection record, and floor location.
• ✓ Rehearse how the escort will move through the site without interrupting production or bypassing required PPE, access controls, or safe-work practices.

Ongoing: keep the answer true after the inspection

• ✓ Close the loop after machine changes, new chemicals, new tasks, incidents, procedure deviations, or training gaps; those events should update the program and trigger retraining or reassessment when required.
• ✓ Track overdue corrective actions visibly so the EHS manager can distinguish an urgent exposure from a documentation cleanup and escalate appropriately.

• ✓ The written program and the floor disagree. A procedure, SDS inventory, hazard assessment, or training matrix describes an older process while employees work around a newer machine, chemical, or task.
• ✓ Evidence exists but is not retrievable. The site has the document somewhere, but no owner can produce the current revision, supporting record, or applicable machine and area within a reasonable response.
• ✓ Employees cannot explain the control. Supervisors know the policy language, but authorized employees cannot describe verification, label meaning, guard limits, PPE limitations, or the escalation path.
• ✓ Visible conditions are normalized. A missing guard, unlabeled container, blocked access path, expired training record, or inconsistent PPE practice has become routine instead of triggering a correction.
• ✓ Program ownership is unclear. EHS owns the policy, maintenance owns the equipment, HR owns the training file, and no one owns the complete answer for the employee or machine being sampled.
• ✓ Corrective actions are not verified. The site records that someone was assigned an action but cannot show completion, effectiveness, or what changed on the floor.

• ✓ Route the visit to the inspection lead. Follow the site’s established process for verifying credentials, notifying leadership, and assigning the trained escort.
• ✓ Keep the opening conversation factual. Identify the scope, areas, records, and people requested; involve the appropriate management or counsel contact when scope questions require a decision.
• ✓ Escort safely and take contemporaneous notes. Follow normal PPE and access rules, record documents and areas sampled, and do not interfere with the inspector’s observations or employee interviews.
• ✓ Answer accurately. Employees and managers should answer what they know, avoid guessing, and say when they need to retrieve a record or confirm a detail. Do not coach, retaliate against, or discourage employees from speaking honestly.
• ✓ Use the closing conversation. Capture the items discussed, document any immediate correction through the normal system, and assign follow-up owners without rewriting the historical record.