what to do when an inspector knocks on your door
DESCRIPTION
What To Do When An Inspector Knocks On Your DoorTRANSCRIPT
KPA – Company Profile
• Nationwide compliance expert on Safety, Environmental, HR
• Colorado Headquarters
• 23 Years Experience
• 3000 + Clients
– Dealerships, Service, Repair
• 20 Offices Serving 41 States
• Compliance products and services
– OSHA
– DOT
– EPA
– Workers’ Comp
– Background checking
– Onboarding
– Harassment
– Red Flags
– Onsite inspections
– Online and onsite training and tracking
– And many more…
Overview
• Why they show up
• Preparing for an inspection
• Visit protocols
Why do they show up?
OSHA & EPA
• Routine (Bad)
• Complaint (Worse)
• Incident (Awful)
DOT
• Air Shipment
• Ground Shipment
• On – Road Incident
Emphasis Programs
• OSHA National Emphasis Programs
– Combustible Dust
– Hazardous Machinery
– Lead
– Silica
• OSHA Local/Regional Emphasis Programshttp://www.osha.gov/dep/local_emphasis_programs.html
• EPA Enforcement Focus
– Stormwater
– Underground Storage Tanks
– Pollution Prevention
Top Violations – OSHA
• Hazard Communication
• Electrical Safety
• General Duty Clause
• Personal Protective Equipment
• Spray Finishing Using Flammables
Top Violations EPA
• Emergency / Spill Response
• Storage Tank Management
• A/C Certifications
• Hazardous Waste Management
• Recordkeeping and Reporting
Top Violations DOT
• Incorrectly Filled Out Shipping Papers
• Shipments by Air
• Training Requirements
• 24 Hour Emergency Number
• Labeling and Packaging Requirements
Be Prepared – Prevention
• Communication – Safety Committees
• Training
• Organized Recordkeeping
• Facility Audits
• Clearly written programs, policies and procedures
OSHA Complaints
• Burden of proof
• Know the requirements
• Drown them in paperwork
• Answer on time
• Promise resolution
During the Visit
• Greet and Identify the Inspector
• Conduct an Opening Conference
• Accompany the inspector during the visit
• Hold a closing conference
Greet and Identify the Inspector
• Employee Training
– Direct inspector to a manager
• Verify Identity
– Name of Individual
– Agency Represented
• Obtain a business Card
• Contact KPA or your EHS Consultant
Conduct an Opening Conference
• Remain Friendly and Professional
• Determine Purpose and Scope
• Notify Inspector of Company Safety Policies and Restricted Areas
• If evidence of serious Hazards or Criminal Activity – Contact Owner/General Manager
Accompany the Inspector
• Guide inspector to areas identified in the opening conference
• Answer questions
– Do not guess
• Limit contact with mis-informed or disgruntled employees
– Any employee may be asked for an interview
– An employee may request representation
During the Inspection (cont.)
• Take notes and observe sampling procedures
– Note any issues of high concern
• Take photographs
• Ask questions
– Do not volunteer information
• Limit documents to those requested
Hold a Closing Conference
• Ask inspector to identify what was found
• Formal report
• Split samples and photographs
• Timeline of next steps
Report and Follow Up
• Write your own summary
– Include recommendation for remediation
• Maintain Communication
• Respond to the formal report
Inspection Resources
• Electronic Code of Federal Regulations
http://www.gpoaccess.gov/ecfr/
• KPA inspection protocol
• OSHA Field Operations Manual
– CPL 02-00-148
• Annual DART Letter
https://www.osha.gov/as/opa/foia/hot_16.html
Important Takeaways
Be Prepared
• Communication
• Accurate paperwork
Take Complaints Seriously
• Respond quickly
• Prove your due diligence
Follow Inspection Protocols
• Identify Inspector
• Opening Conference
• Guided Inspection
• Closing Conference
