“What If?” : How to Ace Unexpected Inspections
“Hello, my name is Bill Hess, and I represent Cornerstone Environmental, Health and Safety. Who is your EHS representative here on site?”
There are a surprising number of places that I “cold call” in person where the front desk employee has no clue who the Environmental, Health, and Safety (EHS) person is or the responsibilities that position holds. If I were an OSHA or Environmental Regulatory Inspector, that person and the company would be off to a very bad start to their day.
In my role with Cornerstone as Manager of Business Development for our Northern Midwest Region for the past 25 years, I have probably visited and prospected over a thousand sites in person. These visits are often unannounced, and I fit them in between other scheduled meetings that I have. Given the turnover rates that many companies experience these days, it’s really no surprise that the front desk person does not know the key people in their organization. However, the front desk person (if there is one) or whoever answers the lobby phone should be well informed of who the facility EHS Manager is and know how to reach them.
In the case of regulatory inspections, it is critical to get off to a good start. First impressions can set the tone of the entire day. Facility management has a responsibility to coach gatekeepers with how to handle an unannounced inspection, and how to manage the inspector until the appropriate EHS person can arrive to meet them. Understanding the importance of this initial interaction is crucial. A respectful and knowledgeable greeting shows the inspector that your organization takes compliance seriously.
Your EHS Manager should also be instructed as to how to manage the inspection. Some simple guidelines include:
Be Cooperative. Throughout the inspection process, your attitude should be one of cooperation. If corrective actions can be taken care of during the inspection, then get it done by you or someone else who is capable.
Just answer the question. Do not elaborate, tell stories, or reveal anything but what is asked or needed. “Loose Lips Sink Ships” is still true in 2024.
Stay on the path. Many inspectors are curious about your operations, but you need to keep them on the path to where they want to go or for what they want to see. This does not need to be a full-day tour unless they state that it is a wall-to-wall inspection.
Monitor pictures. If the inspector takes photos, they may need your permission if it involves proprietary technology or materials. Be sure to take the same pictures they have taken for your own defense.
Take good notes. You may be paying attention to everything during the inspection, but the written report you get from the inspector may take weeks for them to complete. Your notes should match their notes, so don’t rely on your memory for details.
Closing Conference. Be sure to address any questions that you have or that the inspector has during the closing conference. If additional information is needed, establish a date for when it can be delivered to the inspector.
In summary, be prepared and organized. Getting off to a good start could make your day.