The inspector will see you now, so are you ready to be inspected?
If you haven’t thought about the potential for a surprise inspection from a state or federal Environmental Health & Safety agency—such as the U.S. Environmental Protection Agency or U.S. Occupational Safety and Health Administration—until an examiner shows up at your facility, you’ve waited too long. And keeping your fingers crossed or rubbing your good luck charm hoping that you won’t be subjected to an inspection isn’t a sound strategy either.
As Jamie White, a managing consultant for Trinity Consultants, explained in Sphera’s recent webinar titled “What to Expect When You Are Inspected,” many times an audit is triggered by public complaints about unusual odors or something along those lines coming from a nearby facility, so it’s important to be proactive rather than reactive in case your operation is subjected to an inspection. Also, once you’ve been inspected, depending on how it went, you might get a follow-up inspection as well.
“It’s really important to just be prepared, make sure that your records are complete and they’re readily available,” White said. “Make sure your personnel are aware of EHS impacts and how it relates to their jobs. Make sure that signs and labels are available at your facility, and they’re clear and they’re in good condition to be read.”
Basically White advises you to take your EHS “housekeeping” and awareness seriously.
To get ready for a potential inspection, some companies run their own internal inspections or hire a third-party agency to do it for them, which is an excellent strategy. But to get you ready for even an internal inspection, White offered several EPA/OSHA inspection tips during the webinar.
Here are the top 5 EPA, OSHA inspection readiness tips revealed by White during the webinar.
- 1) Appearance Matters: When an inspector visits your facility, it is crucial that you appear confident that you’re being compliant. If an inspector senses you are hindering or interfering the process in any way, they are much more likely to be suspicious, and a more thorough, time-consuming examination of your operation is a definite possibility. Having organized records that are easily accessible will give the inspector a good first impression of your facility.
- 2) When Your Environmental Manager Is Away …: Just your luck, your environmental manager is on a vacay, and you have an EPA inspector in your lobby. It’s a good idea to explain that fact to the inspector off the bat. It’s good to be upfront about such matters, but it doesn’t necessarily mean that they are going to be more lenient or change their strategy. That’s why it’s mega-important to have backup plans in place when your environmental manager is away. Who’s next in line, and can that person seamlessly step in should there be an inspection?
- 3) Here a Hazard, There a Hazard …: Make sure to let the inspector know where any potential hazards are. Also, if there’s an area that your company requires steel-toed boots to enter, let the inspector know. If you don’t have extras boots to lend, it’s OK to let the inspector know that the area is off-limits for safety reasons.
- 4) Bingo on Lingo: It’s entirely possible that an inspector will want to talk to employees during an inspection. That’s why it’s important to train workers about potential EHS issues in your facility. That said, it’s just as important to have a “translator” on-site who speaks the EH&S language. If, for instance, an inspector asks about an aerial lift, but the employee isn’t familiar with the term or knows it as a JLG, which is actually the name of a manufacturer, that could be problematic. However, you should let employees know that they have rights during an inspection. They can decline to be interviewed or request that a manager is present during an interview as well.
- 5) Don’t Be Camera Shy: If an inspector takes a photo at your facility, you should take a similar photo as well. Basically, document everything the inspector is eyeballing for your own records. That way you can get a better picture of what the inspector is focusing on if there’s a penalty to be assessed.