Back in 2017 I posted on how to answer an OSHA document request from the published NEP.
OSHA’s published CPL-03-00-021 – “PSM Covered Chemical Facilities National Emphasis Program” includes an example document request list that often correlates fairly well to the one that OSHA inspectors provide during an NEP inspection.
Recently, a friend sent me the Document Request they received at the onset of the inspection which was quite a bit different from that PSM ChemNEP. Here’s what I noticed reviewing this new document:
- It’s quite a bit longer.
- The information – again – isn’t NH3 Refrigeration Specific. That means you have to interpret some of it.
- In my opinion, It’s designed to be a huge fishing expedition.
I took that request and modified it to show how I would answer the 110 questions if you were using my PSM programs. You can download the 13 page, 4,500 word Microsoft Word monstrosity through the following link: 0419 OSHA Document Request.
Just a few general warnings about questions and document requests:
- When in doubt, ask for clarification. Always get clarifications in WRITING.
- When you are unsure of the appropriate documentation to provide, or what documentation addresses the issue, ask to get back to them and seek quality advice.
- Always get additional documentation requests and follow-up questions in WRITING.
Remember, you can watch a 30 minute presentation on YouTube regarding preparing for (and surviving) an OSHA / EPA inspection here.