What Happens During an OSHA Inspection: Step-by-Step Guide

An OSHA inspection consists of four phases: the opening conference, the walkaround inspection, the document review, and the closing conference. The compliance safety and health officer (CSHO) arrives unannounced, presents credentials, explains the purpose of the visit, physically inspects the jobsite for hazards, reviews your documentation and records, and concludes with a summary of findings and next steps.

Understanding each phase helps you respond effectively, exercise your rights, and ensure your documentation is accessible when requested. Below is a step-by-step breakdown of the full inspection process for construction sites.

Phase 1: Arrival and Credentials

An OSHA inspection begins when a compliance safety and health officer arrives at your jobsite. The inspector will present official OSHA credentials — a photograph and serial number on a U.S. Department of Labor identification card. You have the right to verify these credentials before allowing access.

Inspections are almost always unannounced. Advance notice is a criminal offense under the OSH Act, with very limited exceptions (imminent danger situations, inspections requiring specialized equipment, or cases where access requires the employer's cooperation after hours).

The inspector may be conducting one of several types of inspections, prioritized in this order:

1. Imminent danger — Situations where workers face immediate risk of death or serious physical harm
2. Fatality or catastrophe — Investigations following a death, three or more hospitalizations, amputation, or loss of an eye
3. Employee complaints — Written complaints alleging specific hazards, which OSHA is required to investigate
4. Referrals — Leads from other government agencies, media reports, or other inspections
5. Programmed inspections — Scheduled inspections of high-hazard industries and worksites selected through national or local emphasis programs

Phase 2: The Opening Conference

After credentials are verified, the inspector conducts an opening conference. This is a brief meeting where the CSHO explains:

• The reason for the inspection (complaint, programmed, referral, etc.)
• The scope of the inspection (what areas and standards they plan to review)
• What documents they will need to review
• Your rights during the inspection process

During the opening conference, the inspector will typically request an employer representative to accompany them during the walkaround. This is your right — and you should exercise it. The employer representative should be someone familiar with site operations and safety procedures, ideally the site superintendent or safety manager.

Key actions to take during the opening conference:

• Designate your representative — Have a predetermined point person who knows the inspection protocol. This person should accompany the inspector throughout the entire visit.
• Take notes — Document everything the inspector says, including the stated reason for the inspection, the scope, and any specific areas of concern.
• Ask questions — Understand what the inspector is looking for so you can begin gathering relevant documentation while the walkaround proceeds.
• Notify management — Alert company leadership and, if your company has one, legal counsel that an inspection is underway.

Phase 3: The Walkaround Inspection

The walkaround is the physical inspection of the jobsite. The CSHO will walk through active work areas observing conditions, talking to employees, taking photographs, and noting potential violations.

During the walkaround, the inspector may:

• Photograph conditions — Both compliant and non-compliant conditions. You have the right to take your own photographs of everything the inspector photographs.
• Interview employees — The inspector can speak with employees privately. Employee interviews are confidential, and you cannot be present or listen in. However, you can speak with employees afterward (without coaching them or retaliating).
• Take measurements — Guardrail heights, trench depths, distances from power lines, noise levels, air quality samples, and other quantifiable conditions.
• Observe work practices — How employees use equipment, wear PPE, follow procedures, and interact with hazards.
• Expand the scope — If the inspector observes a hazard outside the original inspection scope, they can and likely will expand the investigation to include it. A complaint-based inspection for fall protection can become a comprehensive inspection if other hazards are observed.

During the walkaround, your representative should:

• Accompany the inspector at all times
• Take parallel photographs and notes of everything the inspector documents
• Answer factual questions honestly but avoid volunteering information beyond what is asked
• Note any employee names the inspector speaks with
• Correct hazards immediately if possible — fixing a hazard during the inspection does not prevent a citation, but it demonstrates good faith and can influence penalty severity

Phase 4: Document Review

At some point during the inspection — often during or immediately after the walkaround — the inspector will request documentation. The specific documents requested depend on the type of inspection and the hazards observed, but common requests include:

• OSHA 300/300A/301 logs (current year and prior five years)
• Written safety and health programs (fall protection, hazard communication, excavation, scaffolding, etc.)
• Training records with dates, topics, trainer qualifications, and employee signatures
• Equipment inspection records (scaffolds, excavations, cranes, fire extinguishers)
• Competent person designations (written documentation identifying the competent person for each applicable standard)
• Incident and near-miss reports with corrective action documentation
• Daily site logs and inspection records
• Subcontractor safety qualifications and oversight documentation

The speed and completeness of your document production matters. Inspectors form impressions about the quality of your safety management based on how quickly and thoroughly you can produce records. Organized, readily accessible documentation signals a disciplined safety program. Delays, missing records, and disorganized files signal the opposite.

Phase 5: The Closing Conference

After completing the walkaround and document review, the inspector holds a closing conference. This is your opportunity to understand what was found and begin preparing your response.

During the closing conference, the inspector will:

• Summarize the conditions observed and potential violations identified
• Discuss possible citations and the standards involved
• Explain the abatement process and timelines
• Describe your rights, including the right to contest citations and request an informal conference

The closing conference does not result in immediate citations. OSHA has up to six months from the date of the inspection to issue citations. During this period, the CSHO prepares a case file, the area director reviews it, and penalties are calculated.

What Happens After the Inspection

After the closing conference, the process unfolds over days to months:

1. Citation issuance — If violations are found, OSHA sends citations by certified mail. Each citation describes the violation, the applicable standard, the proposed penalty, and the required abatement date.
2. 15-working-day response window — You have 15 working days from receiving the citation to respond. You can accept the citation, request an informal conference with the area director, or file a formal notice of contest.
3. Informal conference — A meeting with the OSHA area director to discuss the citations, penalties, and abatement dates. This is often where penalties are negotiated and reduced. Having organized documentation to present at this stage can significantly reduce your financial exposure.
4. Formal contest — If you disagree with the citation, you can contest it before the Occupational Safety and Health Review Commission (OSHRC). This initiates a legal proceeding that can result in the citation being affirmed, modified, or vacated.
5. Abatement — For accepted or uncontested citations, you must correct the hazard by the abatement date and submit proof of correction to OSHA. Failure to abate can result in additional penalties of up to $16,550 per day.

Why Inspection Preparedness Is a Documentation Problem

The inspection process reveals a fundamental truth: OSHA evaluates what you can prove, not what you practice. The walkaround captures conditions at a single point in time. The document review captures your history of safety management.

Contractors who maintain consistent documentation — daily logs, training records, inspection forms, incident reports — enter the inspection process with a defensible position. They can demonstrate ongoing compliance, earn penalty reductions, and contest questionable citations with evidence.

Contractors without organized documentation enter the process exposed. Every assertion they make about their safety practices requires evidence they cannot produce. The inspection becomes a one-sided evaluation based solely on the inspector's observations, with no countervailing record to provide context.

The time to prepare for an OSHA inspection is not when the inspector arrives. It is every day before that. An inspection checklist and consistent daily documentation are the foundation of inspection readiness.