Regulatory inspections are most successful if they are conducted in a non-confrontational atmosphere and are conducted in accordance with an organized format. The following is a general summary of recommended actions for University of Pennsylvania personnel involved in an environmental agency inspection.
Politely verify the inspector's credentials upon arrival. Ensure that you obtain the names, addresses and telephone numbers of the inspector (e.g., obtain business card). Always ensure that a knowledgeable person is available to answer questions and accompany the inspector(s) at all times during facility inspection tours, personnel interviews, records reviews and sampling activities.
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Contact the building
administrator and Environmental
Health and Radiation Safety if an inspector arrives. In
all inspection situations contact EHRS (215.898.4453) and
the Office of the General Counsel (215.746.5200) informing
them that an inspection is taking place. Conduct a
post-inspection briefing for these personnel if they are
unable to accompany the inspectors.
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Before commencing other activities, request a pre-inspection meeting to determine the nature and extent of the inspection. The inspector(s) may merely wish to speak with a qualified person to clarify a technical issue, may wish to review records for a particular program, or may wish to visit operating areas of the facility to verify compliance with a regulatory requirement. Politely ask the inspector(s) to describe the purpose of the visit, the information that he/she must obtain, and the reason why the inspection is taking place. Structure the visit to bring the inspector(s) directly to the information that he/she needs to obtain.
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Ensure that the inspector follows the safety procedures established for your facility or work area (e.g., safety glasses, hearing protection, etc.). Specialized training may be required for access to certain areas of your facility. Do not allow entry into manholes, confined spaces, or high hazard areas (e.g., exposure to high voltage or rotating machinery) without contacting EHRS for guidance.
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The University of Pennsylvania representative escorting the inspector(s) should immediately introduce the inspector to other University of Pennsylvania personnel in a way to ensure that the University of Pennsylvania personnel are (a) alerted to the seriousness of the inspection, (b) the official nature of the inspection, and (c) the items that the inspector will be focusing on. For example, you might introduce an EPA inspector to a lab director as follows: "Hello, Mr. Lab Director. This is Mr. John Inspector, from the Federal Environmental Protection Agency. He is here today inspecting University of Pennsylvania's hazardous waste handling procedures, and he would like to inspect your facility. He is interested in how your facility ensures that chemicals are handled properly before and after use, how you ensure that chemicals are managed as hazardous waste, and the fact that people working in your facility have received training in the proper use of chemicals. You might like to accompany us so you can answer any questions that Mr. Inspector might have."
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To the extent possible, limit the size of the group dealing with agency personnel. Respond to the inspector's questions honestly, directly, and succinctly; the inspector will tell you if elaboration is needed. Provide only the information that is requested. Provide answers where requested, but if you don't know the answer to a particular question, inform the inspector that you do not have the answer. It is usually best to avoid speculation or conjecture when you are unable to provide a knowledgeable answer. Either obtain the answer from someone who can respond and provide the answer to the inspector yourself, or tell the inspector(s) that you will provide a response at a future time after consulting appropriate personnel.
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Agency inspectors may wish to interview personnel to verify that a required training has been provided, to verify operator competency, to determine if established procedures are being followed, or for other purposes relevant to the inspection. Ensure that your personnel follow the Identification, Notification and Communications guidelines listed above.
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Agency inspectors may wish to examine or photocopy records, or photograph processes or conditions that they observe during the inspection. If photography is prohibited in your area seek to accommodate the need for photographs as requested by the inspector. If the inspector takes photographs or photocopies records, obtain your own set of duplicates for later review.
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Agency inspectors may wish to obtain samples of environmental media (e.g., wastewater discharges, building materials, waste materials, air quality, etc.) during the visit. Contact EHRS for assistance with sampling, required chain-of-custody paperwork, analyses or other aspects of the sampling. Obtain a duplicate sample at the same time as the inspector(s). If specialized sampling equipment or procedures are required, request that the inspector return as soon as you are able to provide a person with the specialized equipment or knowledge. Many agencies will sometimes, but not always, agree to this request.
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Request copies of sample analyses performed by the inspector. Depending on the specific analysis, results may be available either during or after the inspection. This information may or may not be provided upon request, depending on the nature of the sampling and agency policy.
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Hold a post-inspection
closeout meeting at the conclusion of the visit to review
the inspector's findings. It is recommended that the
closeout meeting be attended by facility management
personnel and representatives from
EHRS and the Office
of the General Counsel. Ask the inspector(s) to
provide a list of findings, with particular attention to
issues or areas that the inspector has found to be in
actual or possible non-compliance. Ensure that you record
these findings. Do not make any conclusion or judgement
regarding the compliance status of the finding yourself;
that task should be done only by qualified specialists.
Ask the inspector(s) if additional actions or
correspondence will take place and the schedule for any
follow up actions, decisions, or information
development.
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It is recommended that any suspected non-compliance issues be corrected immediately, and that documentation of same be maintained by the facility.
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