Enforcement and Inspection

Tips for a Smooth Agency Inspection

Here are some tips for dealing with agency inspectors at your facility.

Designate a manager and backup to handle inspections. This is the person the receptionists should call ASAP to notify of the arrival of any inspection personnel.

Request the inspector’s credentials and make a copy of them. Business cards are not enough; in fact, if someone shows a card that says “OSHA” or “EPA” but doesn’t show credentials, you should call the FBI with the information. Verify this person’s identity by checking with the nearest regional office if you have any doubts.

If you are being investigated because of a complaint, you should ask the compliance officer to see a copy of the complaint.

Ask about the purpose of the inspection and the applicable standard. This should help you determine what parts of the facility the inspectors seek access to. Ask if the inspection will include documents.

Restrict the inspection to the stated purposes and legally required reports and files.

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Call your lawyer.

Decide whether to invoke a right to insist on a search warrant.

Record the names of all persons conducting or attending the inspection.

Discourage tape recordings.

Conduct any monitoring or take any samples at the same time the inspectors do and label them. Also take duplicate photographs or arrange, in writing, for duplicates to be provided from photos taken by the inspector.

Use the most direct route to the areas the inspector wants to see, avoiding other parts of your facility whenever possible.

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Watch out for any out-of-the-ordinary, nonroutine inspection, especially by a team of agency personnel.

Your management representatives should be cooperative but instruct them not to volunteer information.

Your management representatives should take notes covering everything that is said during the inspection.

Inquire if any violations or deficiencies have been found by the inspector.

In tomorrow’s Advisor, we’ll give you even more practical tips for handling agency inspections.