(108e) Challenges in Hosting An NEP Inspection

An NEP inspection can be very resource intensive; OSHA has received over well over 10,000 pages of documentation at one refinery during an NEP inspection. Developing a strategy that aligns with your corporate governance and protocols could be the key to a successful outcome. The strategy should include the pre-determined tactical plan for the overall response to each inquiry from OSHA. The tactical plan will govern the inspection process, but must align with the overall strategic intent.

You need to be ready to welcome, escort and work with OSHA inspectors from the moment they arrive at your facility until they finish the inspection, to ensure OSHA hears the right answers and your resources are used efficiently.

Your inspection management team will need procedures to check credentials, escort the inspectors, to provide documents, to take photographs, to plan interviews, to respond to findings, to track your actions and to communicate inspection progress to the workforce, management and maybe the public.

You will need to train all the personnel that may interface with the agency on their role and their rights under OSHA.

OSHA has a plan (NEP) to inspect your facility; you need a plan to manage that inspection!