How to Avoid Inspection Fines

How to Avoid Inspection Fines

Moderator

Becky Ross

Marketing Manager

(303) 228-8753

[email protected]

Presented By

Trevor Stage Channel Partner Manager

[email protected]

303-228-2382

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.