Those who work with hazardous materials or in other regulated areas — like all in the collision repair industry do — need to be prepared for a possible inspection by a government agency, such as the Occupational Safety & Health Administration (OSHA) or the Environmental Protection Agency (EPA).
An inspection can be a good thing, if a shop uses it as an opportunity to assess safety practices, and follows recommendations to improve those practices. On the other hand, an inspection can be a bad thing, if management just sees it as another way "the man" is coming down on the shop. This attitude could lead to unsafe conditions and environmental hazards, among other things.
Some inspections will be known, planned events; others will be random surprises. In fact, contacting local authorities and asking them to help you get your shop in order before any citations are issued is a great way to build a positive relationship with those groups overseeing your shop.
Since an inspection can theoretically happen at any time, shops must be prepared. According to GMG Envirosafe, a division of Genesis Management Group, a company that offers compliance, marketing and management solutions to the collision repair industry, there are ways shops can survive inspections from state or local agencies.
Be prepared
- If the owner or manager is not or will not be there for the inspection, someone else should be designated to handle it.
- Perform weekly in-house inspections. Good housekeeping is important.
- Be sure to keep all records current, filed and in order.
When an inspector arrives
- Welcome the inspector and be professional, cooperative and courteous.
- Check credentials.
- Ask why you are being inspected. Do not ask who reported your company.
- Only answer the questions the inspector specifically asks. Never volunteer any information.
- For OSHA inspections, you'll need several documentations. Be prepared to show the OSHA 300 Form (Injury Log) for the past five years, training and safety meeting records, a Material Safety Data Sheets (MSDS) binder, written programs and documentation.
- For EPA inspections, be prepared to show hazardous waste manifests, pick-up receipts for other waste streams and recycling records. Always keep all containers closed and labeled.
- Also make sure you have all the above documents for other inspections (county, fire, state, local, etc.)
- If the inspection is a result of a complaint, the officer may just want to go to the area that involves the complaint. Focus solely on that.
Walk-through inspections
- Accompany inspectors as they go through your shop. Do what the inspector does — take pictures, notes, measurements, etc. This information could be handy to argue against any cited infractions.
- Correct any and all violations immediately, whenever possible.
- After an inspection, collect all information and keep it properly filed and in a safe place. You never know when you're going to need that material.
For more information on surviving OSHA, EPA or other regulatory agency inspections, visit
www.gmgenvirosafe.com.
