OSHA, EPA, & State Agencies - Inspection
Several agencies (OSHA, EPA, or your state agency) can inspect at any time - without notice. Sometimes they will give you a heads up as a courtesy.
Consider the following:
- Open a conference - Greet the agency person and get their information (business card, phone, email, etc.)
- Restrict admittance to your plant until management personnel are on site - prepare receptionists, guards, regular employees, etc. so that managers are made aware of the agency(s) presence on site.
- Determine the inspection reason - Is the visit complaint-based, fatality-based, random, target, or media-based.
- Obtain copies of complaints from the visiting agency - Normally they will have copies/paperwork ready for you when they show up.
- Determine the scope - Ask specifically what the agency is looking for (Safety, Industrial Hygiene, Stormwater, SPCC, Air, etc.)
- Limit the scope - After the initial scope of the inspection is determined confine the visit to just the areas needed from the visiting agency - DO NOT OFFER A PLANT TOUR.
- Maintain your records - Generally, the inspectors are looking for current year PLUS three years back. Some files may have a longer retention rate. If you are an Apex EHS customer your files are hosted on this website by logging in and clicking your tab for safety (not all customers will have this).
- Take photos/video/notes - If the regulator is taking photos or video you should as well - if you have trade/process secrets at your place of business make that information known to the visiting agency beforehand. Also, take pictures and video safely and do not put yourself in harms way to snap a photo. Make detailed notes of what the visiting agency personnel is talking about (also, if they do not have a business card please write any/all information down).
- Debrief your employees - Inspectors can privately interview your employees; therefore, you will need a plan of action if this happens.
- Fix things - If the visiting agency is telling you about some infractions you can delegate to your employees to fix it during the inspection.
- The final conference - Discuss any possible issues before they are put into the inspection report or notice of violation.
*If you are an Apex EHS customer already you can forward us the report(s), NOV, photos, video, etc.
*If you are an Apex EHS customer already you can find your files by logging into this website.