Former OSHA inspector describes how they interview employees
During an inspection, OSHA will interview employees, so what do they ask? A former OSHA inspector shared her experience, noting that OSHA may ask employees about their role, hazards in their work, and whether their training is effective.
“The major part of employee interviews is determining if they have adequate training required for their role,” said Holly Pups, a former Compliance Safety and Health Officer (CSHO) in North Carolina. “The goal is to understand the expectations of management and how safety and health are handled at the employee level.”
During interviews, Ms. Pups often found a disconnect between management and employee expectations. “Employers often had a training program that employees were either insufficiently trained on or didn’t even know about,” she said. In fact, the most common citations she wrote involved insufficient training.
“A company can have extensive training programs and top of the line tracking systems, but it all boils down to this: how do safety training, programs, and culture roll down to the employee level? Often, managers can talk about how great their safety program is, but the enthusiasm falls short where it really matters at the employee level.”
Ms. Pups noted that questions aren’t limited to “have you been trained?” but dig in to understanding of the material. For example, asking about LOTO training includes how often they’ve been trained, when they last received training, who provided that training, and asking the employee to walk through the LOTO process for a machine.
Interviewing multiple employees helps determine how well safety translates through all levels of the company. Some employees talk more than others, which is one reason for interviewing multiple employees — the CHSO gathers a more complete picture of the situation. Interviews may last a few minutes or several hours.
Accident investigations
If the inspection resulted from a reported injury, CSHOs will ask to interview any victims and witnesses to an accident. They’ll also talk to other employees who may do the same job or work in the same area. The CSHO may ask the employer to choose employees for interviews, or may pick employees at random. Other interviews may happen throughout the inspection based on the CSHO’s observations.
The CSHO may request training records for any employees involved in an accident and for others interviewed. If employees were trained only during orientation and now operate heavy machinery, perhaps the training was not sufficient. If an employee was injured using equipment despite documented training records, perhaps the training was not as good as it seemed.
Management interviews
Management interviews happen throughout the inspection, often without a formal request for an interview. Whenever a member of management is talking to the CSHO, the manager should consider it a formal interview, not a casual conversation. The CSHO is checking management’s involvement and awareness of injuries, accidents, and programs. In short, the CSHO is evaluating the upper half of the company’s safety culture.
Topics of discussion are often training programs, accident corrective actions, and much more. These discussions create a reference point for the CSHO to compare to what happens on the employee level once the walkaround and employee interviews occur. Employer knowledge of a hazard is critical when citing a violation.
Key to remember: One goal of conducting employee interviews is to identify any disconnect between what management thinks is happening and what is actually occurring on the shop floor level.
