b'YOUR TOOLKIT FOR BUILDING EXCELENCEOSHA IS ON MY JOBSITEWHAT SHALL I DO?Part IBY Gary AumanNFBA Legal CouncilIfinished a program which included athat fact. This suggested approach just mock OSHA site inspection, a mock informalapplies whether the person is in conference, and a mock OSHA trial for oneor out of their vehicle. If nothing of my clients. This was intended as a teachingelse, the crew leader should point effort for those who had never been through theout to the unidentified person that since this is OSHA site inspection process. I was surpriseda construction site, visitors are not permitted, at the questions I was asked by the attendeesand that the person should leave the area. If, as it at this session, but I was even more surprisedusually is and the site is private property, the site by the number of attendees who felt this typesupervisor might suggest that fact and point out of experience should be made available at eachthat the person is trespassing and again, should annual gathering of this group. The comment andleave the area. Of course, if the person is parked the questions confirmed my belief that very fewon public property such as along a public road, employers, if any, who have never been throughyou will not be able to make them leave. Should an OSHA inspection, have any idea about whatthey elect to stay, and the supervisor knows that is involved in the inspection and after. they are an OSHA compliance officer, I suggest So, I am going to take a few paragraphs to walkthat the crew be directed to take an unscheduled you through this process. First, we have the arrivalbreak while the site supervisor contacts company of the compliance officer to the job site. Mostmanagement for directions. DO NOT FORGET compliance officers will announce their presenceif you keep working, and any of your employees on the jobsite and ask to speak to whomever is inare working unsafely, the compliance officer is charge. However, be aware that there are timesbound to issue a citation for the observed unsafe when a compliance officer will sit in his/heractivity. This may occur even if you have not vehicle observing the crew working for a periodpermitted the inspection to proceed, or if the of time before he/she confronts anyone. For thiscompliance officer is not on the property on reason, the site supervisor should always keep his/ which you are working.her eyes open, and if he/she sees an unfamiliarAs we proceeded with the mock inspection, the vehicle pull into the crew parking or walk up tofirst question I was asked addressed the idea that the jobsite from down the road, they shouldthe employer can have the compliance officer approach the individual and ask if they can be of(hereinafter the CSHO) wait a reasonable period assistance. There is nothing wrong with askingof time for a management representative to get the unidentified person who he/she is. If they areto the site to direct the companys involvement an OSHA compliance officer they must admit toin the inspection. But, what can you do? You, the continued on page: 32 FRAME BUILDER - JAN2020 / 31'