What To Do When An Inspector Knocks On Your Door
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What To Do When An Inspector Knocks On Your Door

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What To Do When An Inspector Knocks On Your Door

What To Do When An Inspector Knocks On Your Door

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What To Do When An Inspector Knocks On Your Door What To Do When An Inspector Knocks On Your Door Presentation Transcript

  • Presented By Peter Zaidel KPA Product Manager pzaidel@kpaonline.com 303-228-2397
  • 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 View slide
  • Why do they show up? OSHA & EPA • Routine (Bad) • Complaint (Worse) • Incident (Awful) DOT • Air Shipment • Ground Shipment • On – Road Incident View slide
  • Emphasis Programs • OSHA National Emphasis Programs – Combustible Dust – Hazardous Machinery – Lead – Silica • OSHA Local/Regional Emphasis Programs http://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
  • Contact Information www.kpaonline.com info@kpaonline.com 866-356-1735