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OSHA 1960.25

Inspector qualifications and inspections

Subpart D

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1960.25(a), who qualifies to conduct safety and health inspections in federal workplaces?

Qualified inspectors are personnel who have the equipment and competence to recognize hazards and who can evaluate them and recommend general abatement steps. This is stated in 1960.25(a), which also notes that safety and health specialists defined in 1960.2(s) with experience or up-to-date training meet the qualification requirement.

Under 1960.25(a), can inspectors without specialized credentials inspect low-hazard workplaces?

Yes — for less complex hazards, inspectors do not always need a specialized safety and health certification, but they must have sufficient documented training or experience to recognize and evaluate the specific hazards present and to suggest general abatement. This flexibility is described in 1960.25(a).

Under 1960.25(a), what does 'sufficient documented training and/or experience' mean for an inspector?

It means the inspector must have records showing training courses, on-the-job experience, or other documented learning that enables them to recognize and evaluate the particular hazards in that workplace and to recommend general abatement measures. The requirement for documented training or experience is specified in 1960.25(a).

Under 1960.25(a), what equipment must inspection personnel be given?

Inspection personnel must be provided the equipment necessary to conduct a thorough inspection of the workplace involved. 1960.25(a) requires agencies to supply inspection personnel with appropriate tools and instruments for identifying hazards.

Under 1960.25(a) and 1960.2(s), are "safety and health specialists" automatically considered qualified inspectors?

Yes — safety and health specialists, as defined in 1960.2(s), who have experience and/or current training in hazard recognition and evaluation are considered to meet the qualifications of safety and health inspectors under 1960.25(a).

Under 1960.25(b), what must an agency do when a workplace contains classified information?

The agency must provide access to safety and health inspectors who have obtained the appropriate security clearance to enter those workplaces. This requirement is explicit in 1960.25(b).

Under 1960.25(c), how often must federal workplaces be inspected?

All areas and operations of each workplace, including offices, must be inspected at least once every year, and more frequently where work increases the risk of accidents, injuries, or illness. This inspection frequency is set out in 1960.25(c).

Under 1960.25(c), do inspections need to be unannounced and include follow-ups?

Yes — agencies should conduct sufficient unannounced inspections and unannounced follow-up inspections to ensure hazardous conditions are identified and abated. That expectation is described in 1960.25(c).

Under 1960.25(c), are office areas required to be included in inspection programs?

Yes — 1960.25(c) explicitly requires that all areas and operations, including office operations, be inspected at least annually.

Under 1960.25(d), how should agencies handle inspections when multiple agencies share responsibility for a safety condition?

Agencies are encouraged to coordinate inspection functions when multiple agencies have responsibilities that affect employee safety and health. That encouragement is found in 1960.25(d). Coordinated inspections can reduce duplication and ensure clear responsibility for abatement.

Under 1960.25(a), must inspectors recommend abatement measures during inspections?

Yes — inspectors must be able to suggest general abatement procedures as part of their duty to recognize and evaluate hazards, as required by 1960.25(a).

Under 1960.25, can an agency use contractor or temporary staff to perform inspections?

Yes — but contractor or temporary inspectors must meet the same qualification and equipment requirements: they must have the competence, documented training or experience, and the necessary equipment to recognize and evaluate the hazards and to suggest general abatement procedures, per 1960.25(a).

Under 1960.25(c), what triggers more frequent inspections than the annual minimum?

Workplaces with an increased risk of accident, injury, or illness because of the nature of the work performed must be inspected more frequently than once a year. That trigger for increased inspection frequency is stated in 1960.25(c).

Under 1960.25(b), who is responsible for arranging security clearances for safety inspectors in classified workplaces?

The employing agency is responsible for ensuring inspectors who need access to classified areas have the appropriate security clearances and access. 1960.25(b) places the obligation on the agency with the classified workplaces.

Under 1960.25(a), does the standard require a specific certification or degree for inspectors?

No — the standard does not mandate a specific certification or degree; instead it requires that inspectors have the competence, equipment, and documented training and/or experience necessary to recognize and evaluate workplace hazards and suggest general abatement, as described in 1960.25(a).

Under 1960.25(c), what is the role of follow-up inspections after hazards are identified?

Follow-up inspections are intended to verify that identified hazards have been abated; agencies should conduct sufficient unannounced follow-up inspections to ensure hazards are corrected, as directed in 1960.25(c).

Under 1960.25, how should agencies handle inspection coverage for work done by contractor employees on federal sites?

Agencies must ensure inspections cover all personnel working on the site, including contractor employees, and that inspectors are qualified to recognize hazards affecting those workers; see 1960.25(c) for the inspection requirement and 1960.25(a) for inspector qualifications.

Under 1960.25 and Executive Order 12196, do OSHA standards apply to military-only operations and inspectors?

Certain military personnel, unique military equipment, and uniquely military operations are excluded from OSHA coverage under Executive Order 12196, but civilian employees and contractor employees performing non-unique tasks are covered and must follow OSHA standards. This jurisdictional nuance is explained in the OSHA interpretation Oxygen-deficient atmospheres in HVAC, which references Executive Order 12196 and 29 CFR Part 1960.

Under 1960.25(a), what special considerations apply when hazards include confined spaces or oxygen-deficient atmospheres?

When hazards are more complex—such as confined spaces or oxygen-deficient atmospheres—inspectors must have specific training and experience to recognize and evaluate those hazards and to recommend appropriate abatement and protective measures, per 1960.25(a). For issues involving oxygen-deficient atmospheres in federal workplaces where civilian employees are covered, see the OSHA interpretation Oxygen-deficient atmospheres in HVAC for application details.

Under 1960.25(c), what does "sufficient" mean when describing the number of unannounced inspections an agency should conduct?

“Sufficient” means enough unannounced inspections and unannounced follow-ups to reasonably ensure hazardous conditions are identified and effectively abated; the agency must use a risk-based approach (frequency and scope) tailored to the workplace's hazards, as required by 1960.25(c).