Presented By

Peter ZaidelKPA Product Manager

pzaidel@kpaonline.com

303-228-2397

KPA – Company Profile

• Nationwide compliance expert on Safety, Environmental, HR

• Colorado Headquarters

• 23 Years Experience

• 3000 + Clients

– Dealerships, Service, Repair

• 20 Offices Serving 41 States

• Compliance products and services

– OSHA

– DOT

– EPA

– Workers’ Comp

– Background checking

– Onboarding

– Harassment

– Red Flags

– Onsite inspections

– Online and onsite training and tracking

– And many more…

Overview

• Why they show up

• Preparing for an inspection

• Visit protocols

Why do they show up?

OSHA & EPA

• Routine (Bad)

• Complaint (Worse)

• Incident (Awful)

DOT

• Air Shipment

• Ground Shipment

• On – Road Incident

Emphasis Programs

• OSHA National Emphasis Programs

– Combustible Dust

– Hazardous Machinery

– Lead

– Silica

• OSHA Local/Regional Emphasis Programshttp://www.osha.gov/dep/local_emphasis_programs.html

• EPA Enforcement Focus

– Stormwater

– Underground Storage Tanks

– Pollution Prevention

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

Be Prepared – Prevention

• Communication – Safety Committees

• Training

• Organized Recordkeeping

• Facility Audits

• Clearly written programs, policies and procedures

OSHA Complaints

• Burden of proof

• Know the requirements

• Drown them in paperwork

• Answer on time

• Promise resolution

During the Visit

• Greet and Identify the Inspector

• Conduct an Opening Conference

• Accompany the inspector during the visit

• 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

• If evidence of serious Hazards or Criminal Activity – Contact Owner/General Manager

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

– 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

Inspection Resources

• Electronic Code of Federal Regulations

http://www.gpoaccess.gov/ecfr/

• KPA inspection protocol

• OSHA Field Operations Manual

– CPL 02-00-148

• Annual DART Letter

https://www.osha.gov/as/opa/foia/hot_16.html

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

Contact Information

www.kpaonline.com

info@kpaonline.com

866-356-1735