how to avoid inspection fines
DESCRIPTION
How to Avoid Inspection FinesTRANSCRIPT
How to Avoid Inspection Fines
How To Avoid Inspection Fines
• Current trends of regulatory activity
• Top violations and why they show up
• Ways to Be Prepared
• Inspector Visit protocols
Trends in Regulatory Activity
Trends in Regulatory Activity
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
What causes them to show up?
OSHA & EPA
• Routine (Bad)
• Complaint (Worse)
• Incident (Awful)
DOT
• Air Shipment
• Ground Shipment
• On – Road Incident
Are you covered?
Safety Culture drives behavior reduces risk
Safety Culture EXAMPLES
• Management Walk-arounds
• Workplace hazards
• Unsafe behaviors
• In-house Inspections
• Training
• New hire orientation
Be prepared with existing Safety Culture
• Safety Committee Meetings
• Accident Investigation
• Employee Suggestions
Safety Culture
During an Inspection
1. Greet and Identify the Inspector
2. Conduct an Opening Conference
3. Accompany the inspector during the visit
4. 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
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
– Answer when asked but 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
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
KPA arrives unannounced
Thorough Facility Inspection
Interviews 3 facility employees
– 1 Manager
– 2 Employees
Coaching opportunities revealed on the spot
Extensive report generated within
MyKPAonline.com
Protect Your Operations from EPA/OSHA Inspections KPA Introduces: The 5th Visit
• Find out how your facility might fare if
visited by a regulator
• Reveal how well prepared your
employees are to respond to an
inspector
• Uncover management training
opportunities
• Decrease likelihood of potential fines.