inspections on a routine basis. These inspections may be comprehensive, targeted to certain operations or experiments, focused on a particular type of inspection such as safety equipment and systems, or audits to check the work of other inspectors.
Safety staff are not the only nonlaboratory personnel who may conduct safety inspections. Facility engineers or maintenance personnel may add considerable value to safety inspection programs. They are also given the opportunity to gain a better perspective on laboratory work. It is advisable to have a representative from facilities engineering present during inspections so physical deficiencies can be appropriately and clearly noted and understood and priorities set for correction.
2.E.1.6 Inspections by External Entities
Many types of elective inspections or audits are conducted by outside experts, regulatory agencies, emergency responders, or other organizations. They may inspect a particular facility, equipment, or procedure either during the preexperiment design phase or during operations. As a matter of safety and security, if someone requests entry to a laboratory for the purpose of an audit without a recognized escort, ask to see his or her credentials and contact the EHS office or other appropriate parties.
Tours, walk-throughs, and inspections by regulatory or municipal organizations offer the opportunity to build relationships with governmental agencies and the public. For example, an annual visit by the fire department serving a particular facility will acquaint personnel with the operations and the location of particular hazards. If these individuals are ever called into the facility to handle an emergency, their familiarity with it will make them more effective. During their walk-through, they may offer comments and suggestions for improvements. A relationship built over time helps make this input positive and constructive.
If a pending operation or facility change may raise public attention and concern, an invitation targeted to specific people or groups may prevent problems. Holding public open houses from time to time helps build a spirit of support and trust. Many opportunities exist to apply this type of open approach to dealing with the public. An organization only needs to consider when to use it and what potential benefits may accrue.
Inspections and audits by outside consultants or peer institutions are especially helpful to identify both best practices and vulnerabilities. Many times, the inspectors bring with them experiences and examples from other laboratories that prove useful. When choosing a consultant, best practice is to find one with experience conducting similar audits of peer institutions. More and more often, health and safety experts, facilities staff, and laboratory personnel from peer institutions form inspection teams that conduct inspections of each other’s laboratories. Such an arrangement can be beneficial and economical.
Many regulatory agencies promote institutions conducting self-audits, by either consultants or peer auditors, and reporting the findings to the agency. As an incentive, any violations noted in the self-audit may result in reduced or waived fines and fewer visits from the agency inspectors. It is important to fully understand the regulatory agency’s self-reporting policy before implementing this option. In some cases, the institution must commit to remediating identified deficiencies within a specific time period.
Finally, regulatory agencies may conduct announced or unannounced inspections on a routine or sporadic basis. Laboratories and institutions should keep their programs and records up-to-date at all times to be prepared for such inspections. Any significant incident or accident within a facility may trigger one or more inspections or investigations by outside agencies. Evidence that the underlying safety programs are sound may help limit negative findings and potential penalties.
2.E.2 Elements of an Inspection
2.E.2.1 Preparing for an Inspection
Whether an inspection is announced or unannounced depends on the objective. There are many advantages to announcing an inspection ahead of time. By announcing and scheduling inspections, the inspectors are more likely to interact with the laboratory personnel and the supervisors. The inspection can be a good learning experience for all and will feel less like a safety-police action and more like a value-added service, with the right attitude and approach. However, if the objective is to observe real-time conditions in preparation for a regulatory inspection, an unannounced targeted inspection might be appropriate.
Before the inspection, have a checklist of inspection items, along with the criteria and the basis for each issue. The criteria may be based on regulations, institutional policies, or recommended practices. Sharing the checklist with laboratory personnel prior to the inspection helps them perform their own inspections before and periodically after the inspection.
Bring a camera. A photograph is much more effective than a long explanation in convincing a manager that something needs attention.