Policy 11-1-5: Dealing with EH&S Regulatory Agency

Policy: Policy 11-1-5: Dealing with EH&S Regulatory Agency Date Adopted:    
Department: Environmental Health & Safety Date(s) Reviewed and/or Revised:

 February 7, 2025; June 20, 2013; September 2, 2008
Contact: EH&S Coordinator
Statement: To professionally and proactively participate in an unannounced inspection or inquiry at WNC from a government environmental, health or safety entity. The list of entities includes: Nevada OSHA, the Nevada Divison of Environmental Protection, the Local Health or State Board of Health, the State Fire Marshall, and the Environmental Protection Agency. This policy does not apply for Carson City Environmental inspections or inspections relating to construction or a remodel unless the inspection was triggered by a complaint.

Section 1: Responsibilities

  1. Information and Marketing/reception shall greet the government representatives. Information and Marketing/reception will see to it that the Government Representative is met promptly by the EH&S Coordinator. The EH&S Coordinator will inform the Facilities Director, or other appropriate college representatives.
  2. EH&S will immediately meet with the government representative(s). If this is not possible and the Chief Financial Officer, on behalf of the EH&S Coordinator, will meet with the representative(s) and may request a delay in the inspection until the EH&S Coordinator can reach campus. NOTE: If it is an unannounced inspection by Nevada OSHA or the U.S. Federal EPA, it is not unusual to ask for a delay to allow the EH&S Coordinator or other key WNC personnel to fully participate in the inspection.
  3. The EH&S Coordinator or the Chief Financial Officer shall determine the following information from the government representative.
    1. What is the nature of the visit?
    2. If this is a compliant or audit, what specific areas does the regulatory agency seek to inspect?
    3. What College Divisions/Departments should be present at the preinspection meeting?
    4. How long should the inspection take?
    5. What information will be available from the government entity in the post inspection meeting?
    6. What is the probability of citations and fines?
    7. Obtain business cards
  4. If this is an inspection or complaint investigation, the EH&S Coordinator or the Chief Financial Officer should break away from the government representative to notify the involved parties to allow their participation in the inspection and the pre-inspection meeting.
  5. Human Resources shall be advised if the visit involves the investigation of an employee complaint.
  6. Other Administrators and Directors shall participate in the meetings and inspections as required. Items identified during the inspection should be immediately corrected when possible. Bring the required employees and equipment immediately to the location to correct the situation. Have the government representatives acknowledge that compliance was achieved. WNC should take photos. It is important to take photos of items corrected with an occasional photo that includes the government representative. If an educational space needs to be inspected it should only occur when no class or activity is taking place.  Attempt to allow the educational space supervisor to review the educational space prior to the inspection. 

Section 2: Procedure

  1. The EH&S Coordinator and in their absence the Chief Financial Officer shall see that the government representative(s) are greeted and promptly received. In addition they shall inform the Facilities Director and other appropriate college representative(s).
  2. The EH&S Coordinator or the Chief Financial Officer shall determine the reason for the visit/call and determine the scope of the issue or inspection.
  3. As possible, the following participation shall be obtained. In addition to the notification of the Director of Facilities. The following guidelines should be followed for requesting WNC employees to participate.
    1. Board of Health: Child Development Center Director 
    2. Employee Complaint: Human Resources Department
    3. Classroom or Lab Inspections: Academic Director
    4. State Fire Marshall: Facilities Director
    5. Student/Public Complaint: Vice President of Academic and Student Affairs
    6. General Inspection: Facilities Director
    7. Inspections that may Result in Citations or Fines: EH&S Coordinator or Chief Financial Officer
  4. EH&S will always try to schedule a pre-inspection conference and a post inspection exit review. All in attendance will receive copies of the written information provided by the government representative(s).
  5. The interim result of the exit review, if significant, will be shared as soon as feasible with the Chief Financial Officer and any other key personnel that could not attend the exit review.

Section 3: Inspection/Audit Response

  1. The response to regulatory inspections shall be in writing from EH&S Coordinator or from the Cheif Financial Officer, as appropriate.
  2. The response to an employee complaint shall be in writing as required. If the response is not in writing it shall be clearly communicated to all WNC involved parties.
  3. Where appropriate Administrators, and Directors shall review the response prior to issuance.
  4. If fines or penalties are possible, the EH&S Coordinator shall take full advantage of the hearing and appeal process to the extent necessary to mitigate financial impact.

Section 4: Inspection/Close-Out

  1. The EH&S Coordinator shall work with other departments to coordinate completion of inspection and audit findings.
  2. Open inspection findings will be documented in EH&S reports.