5.1 Inspections: who, how often, and what the record is for

1 One sentence, unpacked

29 CFR 1926.20(b)(2): the employer's accident prevention program “shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers.”

And what it does not say: no interval, no form, no retention period. Anyone selling you “the OSHA-required weekly inspection form” is filling in blanks the regulation deliberately left open.

2 Competent person: two halves, both required

1926.32(f) defines a competent person as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”

Somebody who can spot the problem but cannot stop the work is not a competent person, however experienced. That second half is an organizational decision, not a technical one — it means the employer has to give someone the authority in advance and mean it. Compare 1926.32(m), which defines a qualified person by recognized degree, certificate or professional standing, or by extensive knowledge, training and experience demonstrated in solving problems of the subject matter. Different word, different test, and the standards use each deliberately.

3 Where the blanks get filled in

Four sources close the gaps the federal sentence leaves, and they are worth knowing separately because each binds differently.

• State plans. Washington requires a walk-around safety inspection at the beginning of each job and at least weekly thereafter, conducted jointly by one member of management and one employee elected by the employees, documented, with records kept until the job is complete — WAC 296-155-110(9). California requires periodic inspections under its Injury and Illness Prevention Program, with records identifying who inspected, the unsafe conditions found and the action taken, kept at least one year — 8 CCR 3203(a)(4) and (b)(1).
• The contract. On most commercial work the general contractor's requirements set frequency, form and retention, and are usually stricter than the regulation.
• Standards with their own inspections. Excavations daily and after every rainstorm by a competent person (1926.651(k)(1)); scaffolds before each work shift (1926.451(f)(3)); ladders periodically and after any occurrence that could affect safe use (1926.1053(b)(15)); powered industrial trucks before each shift (1910.178(q)(7)). These are separate duties and a weekly walk does not discharge them.
• OSHA's recommended practices. Inspect regularly; have workers on the inspection team; document so corrections can be verified later; use checklists; and include the areas everyone forgets — storage and warehousing, maintenance, purchasing and office functions, and the work of on-site contractors and temporary employees.

4 What the record is actually for

There is no federal retention period for a jobsite inspection record, which makes it tempting to treat the form as optional. It is not, for a reason that has nothing to do with enforcement: the record exists to prove the finding was closed.

OSHA's recommended practices put it plainly — document inspections so that hazardous conditions can later be verified as corrected. That is why a useful inspection form has a corrective action log with an owner, a date and a status, and why the most important column on it is whether work was stopped. A list of findings with no closure column is a list of things you knew about and did not fix, written down in your own hand.

5 Walking it with someone from the crew

The federal rule says nothing about who else comes. Washington requires the walk to be joint. Everywhere else it is the single cheapest improvement available to an inspection, for a reason that has nothing to do with compliance: people who work in a space stop seeing it, and people who do not work in it do not know what normally happens there. Two sets of eyes with different blind spots find different things.

1. 1
   Walk the checklist order, not the site geography — it is how you notice the thing nobody is standing next to.
2. 2
   Mark N/A honestly. A sheet with no N/A on a site with no scaffold is a sheet nobody read.
3. 3
   Fix what can be fixed while you are standing there, and record it as corrected on the spot.
4. 4
   Give every remaining finding an owner and a date before you leave the area.
5. 5
   Write one line about what was right. It costs nothing and it is why the crew points at the next problem.

6 Inspections and the log, joined up

The two halves of this course meet here. An inspection finding and a recordable case are the same hazard at two different stages, and the only difference is whether anyone was standing in the wrong place at the time.

So read them together. If the log shows three struck-by cases in one bay and the inspection sheets for that bay have been clean all year, one of the two documents is wrong. If an inspection finding appears three weeks running and then an incident happens on it, that sequence is the story the investigation will tell — and it is in your own filing cabinet.