Preparing for an OSHA Inspection

By Kathleen Pohlid Founder & Managing Member, Pohlid, PLLC | December 09, 2012

In the past year, state and federal entities conducted over 500 inspections of hotel establishments within the United States for compliance with the Occupational Safety and Health Act. Many of those inspections were initiated by referrals from other governmental entities and from employee complaints. In some cases, establishments were issued citations for safety violations. Since employers are not provided prior notice of onsite OSHA inspections of their workplace, it is important to be prepared and to ensure establishments are in compliance with OSHA standards.

Hotel establishment employers are required under the Occupational Safety and Health Act of 1970 to provide safe and healthful working conditions for their employees and to comply with applicable safety and health standards. In 2010, OSHA added over 100 employees to its existing compliance staff with the stated purpose of increasing inspections. Since an OSHA inspection can be triggered at any time and establishments are not given advance notice of an inspection, it is important to be prepared. Here are some measures to prepare for OSHA and enhance safety and health in your workplace:

Know the Standards that Apply

Employers are required to comply with the safety and health standards promulgated by OSHA which apply to their workplace. These standards are available via OSHA’s website at and include the general duty standards set forth at 29 C.F.R. 1910 and the recordkeeping and reporting standards at 29 C.F.R. 1904. (Employers with ten or fewer employees during the preceding calendar year may be partially exempt from some of the recordkeeping requirements.) The OSHA website also contains valuable information for safety compliance and training programs. Establishments should conduct periodic workplace audits to identify standards that apply to their workplace and ensure they are in compliance with those standards.

Document and Implement Required Written Programs & Records

Some of the OSHA standards require employers to establish written safety programs or rules to address hazards or to maintain records relating to hazardous exposures. For example, 29 C.F.R. 1910.38(b) & 39(b) require employers with more than ten employees to have written emergency action and fire prevention plans and specifically set forth the contents that must be included within such plans.

Coming up in February 2018...

Social Media: Engagement is Key

There are currently 2.3 billion active users of social media networks and savvy hotel operators have incorporated social media into their marketing mix. There are a few Goliath channels on which one must have a presence (Facebook & Twitter) but there are also several newer upstart channels (Instagram, Snapchat &WeChat, for example) that merit consideration. With its 1.86 billion users, Facebook is a dominant platform where operators can drive brand awareness, facilitate bookings, offer incentives and collect sought-after reviews. Twitter's 284 million users generate 500 million tweets per day, and operators can use its platform for lead generation, building loyalty, and guest interaction. Instagram was originally a small photo-sharing site but it has blown up into a massive photo and video channel. The site can be used to post photos of the hotel property, as well as creating Instagram Stories - personal videos that disappear from the channel after 24 hours. In this regard, Instagram and Snapchat are now in direct competition. WeChat is a Chinese company whose aim is to be the App for Everything - instant messaging, social media, shopping and payment services - all in a single platform. In addition to these channels, blogging continues to be a popular method to establish leadership, enhance reputations, and engage with customers in a direct and personal way. The key to effective use of all social media is to find out where your customers are and then, to the fullest extent possible, engage with them on a personal level. This engagement is what creates a personal connection and sustains brand loyalty. The February Hotel Business Review will explore these issues and examine how some hotels are successfully integrating social media into their operations.