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||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 Department 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.|
Table of Contents:
- Inspection/Audit Response
Section 1: Responsibilities
- Information and Marketing/reception shall greet the government representatives unless. 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 representative.
- Environmental Health and Safety will immediately meet with the government representative(s). If this is not possible and the Vice President of Finance and Administrative Services 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 and unannounced inspection by Nevada OSHA or the Federal EPA, it is not unusual to ask for a delay to allow EH&S Coordinator or other key WNC personnel to fully participate in the inspection. Proceeding with the audit or inspection with proper preparation can result in excessive fines and unnecessary penalties.
- The EH&S Coordinator or in his absence the Vice President of Finance and Administrative
Services shall determine the following information from the government representative.
- What is the nature of the visit?
- If a compliant or audit what specific areas does the regulatory agency seek to inspect?
- What College Divisions/Departments should be present at the preinspection meeting?
- How long should the inspection take?
- What information will be available from the government entity in the post inspection meeting?
- What is the probability of citations and fines?
- Obtain business cards
- If this is an inspection or complaint investigation. The EH&S Coordinator or the Vice President of Finance and Administrative Services should break away from the government representative to notify the involved parties to allow their participation in the inspection and the pre-inspection meeting.
- Human relations shall be advised if the visit involves the investigation of an employee complaint.
- Other Supervisors and Academic Directors shall participate in the meetings and inspections as required. All employees should be careful when responding to questions. Such government representative(s) should never be granted unescorted access to the campus.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 the conformance was achieved. If the government representative(s) are taking photos; WNC should also take photos. It is important to take photos of item corrected with an occasional photo that includes the government representative. If a laboratory needs to be inspected it should only occur when no class or activity is taking place. Student and employee actions can precipitate additional violations and fines. In addition, attempt to allow the lab supervisor to review the lab prior to the inspection. Do not bring the government representatives through areas of buildings that may trigger additional inspections.
Section 2: Procedure
- Information and Marketing/reception shall be responsible for the initial positive interface with the government representative(s). They shall contact the EH&S Coordinator and in their absence the Vice President of Finance and Administrative Services to 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).
- The EH&S department or the Vice President of Finance and Administrative Services after being contacted by Information and Marketing/reception shall determine the reason for the visit/call and determine the scope of the issue or inspection.
- As possible the following participation shall be obtained: In addition to the notification
of the Director of Facilities. The following guidelines should be followed.
- Board of Health Child Development Center Director or WNC Sedway Representative (as appropriate)
- Employee Complaint Human Relations Department
- Class or Lab Inspections Academic Director
- State Fire Marshall Facilities Department Representative
- Student/Public Complaint Dean of Student Services
- General Inspection Facilities Representative
- Inspections that may Result in Citations or Fines Information and Marketing
- 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).
- The interim result of the exit review if significant will be shared as soon as feasible with the V.P. of Finance and Administration and any other key personnel that could not attend the exit review.
Section 3: Inspection/Audit Response
- The response to regulatory inspections shall be in writing from EH&S department or from the WNC President as appropriate.
- 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.
- Where appropriate Supervisors, Academic Directors shall review the response prior to issuance.
- If fines of penalties are possible, EH&S shall take full advantage of the hearing and appeal process to the extent necessary to mitigate financial impact.
Section 4: Inspection/Close-Out
- EH&S shall work with other departments to coordinate completion of inspection and audit findings.
- Open inspection findings will be documented in EH&S reports.
|Date(s) Revised||June 20, 2013; September 2, 2008;||Date(s) Reviewed|