[Facility Name]
EHS Inspection Readiness Plan
Revision Date:
Prepared by: ______________________________ Date: _____________
Name, Title
Approved by:
______________________________ Date: _____________
Name
Site Director
______________________________ Date: _____________
Name
EHS Manager
Table of Contents
| Step | Description |
| 1.0 | Purpose |
| 2.0 | Pre – Audit Preparation * Do’s and Don’ts * SharePoint Record * Prep list * Rooms * Walk Throughs * Facility Overview Presentation |
| 3.0 | Communication * On-Site and Off-Site notifications |
| 4.0 | Facility Tour |
| 5.0 | Audit Support Teams * Roles and Responsibilities * Person Responsible |
| 6.0 | Subject Matter Experts (SMEs) |
| 7.0 | Inspection Activities * Document and information flow * End of day activities * Internal Daily Wrap Up |
| 8.0 | Closing Meeting * Attendees |
Purpose
The purpose of this document is to outline the process that [facility name] will follow in the event of a regulatory EHS inspection or other governmental agency visit. The processes within this document are intended to help ensure that the auditor/inspector(s) are promptly meet with, that their intentions or plans are defined and that any requested tours, discussions or requests are satisfied. Additionally, it ensures such requests and deliverables are properly tracked, reviewed, completed and documented . In addition, it ensures that the appropriate individuals are prepared to meet with the auditor/inspector(s), as requested.
This document is intended to provide the specific names of individuals and specific activities for the specific facility.
Pre – Audit Preparation
Inspection training and review of this document should be conducted at least annually by the EHS team. The “do’s and don’ts” of participating in an inspection should be periodically emphasized in staff meetings, Tier meetings, etc.
SharePoint Record
Audits are managed and tracked through [SharePoint/Lighthouse]. To set up a new audit record in SharePoint contact [name of point person].
Do’s and Don’ts
Do:
| Always review documents prior to presenting to the Auditor/Inspector and be familiar with the contents and aware of potential issues you may have to address. | |
| Only share documents that have been requested by the auditor/inspector and that have been first reviewed/approved by the prep room leader or inspection coordinator. | |
| Take cues from Inspection Coordinator and/or coach regarding the approach the auditor/inspector is taking. | |
| Keep responses concise and simple. Limit response to the specific question/comment. | |
| Put your cell phone on silent prior to entering the inspection room. | |
| Auditors/Inspectors shall be treated with professionalism and respect at all times. | |
| Present yourself in a professional and confident manner. | |
| Introduce yourself. | |
| Start by stating: –Name –Job Title –Overall responsibilities of your job | |
| Provide requested documents promptly. | |
| Stay focused, calm, and attentive at all times. Do not allow non-verbal or emotional responses. | |
| Carefully listen to the question asked. Be patient and let the auditor/inspector complete their thought or question. | |
| Ask for clarification if you do not understand or are not clear about the question/request. | |
| Answer only the question asked but be sure that it is a complete response. | |
| Always be truthful, honest, and factual in response to questions. It is acceptable to provide an answer of “I do not know, but I will find out for you.” If you do have the information or do not know the answer, state “I will get the answer for you by {time/day}”. | |
| Refer to the subject matter expert (SME) if you are unsure of the question or our systems. | |
| When using acronyms – in writing or in your discussions –Spell out or explain when first used –Use current acronyms | |
| When delays in requested information or documentation are inevitable, the auditor/inspector shall be advised of the delay and the reason for the delay. |
Don’t:
| Don’t speculate or answer hypothetical questions. If you don’t know the answer, don’t guess or make assumptions. | |
| Don’t argue points of law or regulations. We don’t want to promote an adversarial atmosphere. | |
| Avoid defensive reactions if an auditor observes a non-conforming condition. Acknowledge and explain the observation and determine if immediate remedial action can take place. | |
| Auditors/Inspectors use moments of silence as a prompting tool. Don’t feel compelled to fill the silence. | |
| Don’t withhold information or make assumptions. | |
| Don’t argue or disagree with other team members in front of an auditor/investigator. | |
| Don’t review unofficial records with the auditor/inspector. | |
| Don’t voice personal opinions, views, hearsay or rumors. | |
| Don’t answer your cell phone in the room. | |
| Never sign any documentation or affidavits given by the auditor/inspector. | |
| Don’t leave an auditor/inspector unaccompanied, especially in an operations area. | |
| Don’t agree or volunteer to change a procedure without first discussing it with management. | |
| Don’t engage in conversations regarding issues within earshot of the auditor/inspector. | |
| If you are part of the support team, do not leave the facility during the inspection for any reason, unless approved by the prep room leader(s) or the EHS manager. This includes lunch or other breaks. |
Most important: LISTEN, THINK, and TELL THE TRUTH
Items that may not be reviewed by an auditor/inspector during an agency (external) inspection:
-
- Management Review Meeting Minutes (other than procedure, agenda topics, and attendance roster)
- Financial, sales, pricing, and cost data
- Personal data (except training record and curriculum vitae / resume related to the qualification / technical expertise of personnel)
- Research data for which regulatory license has not been approved
- Shipment records (specific written request must be obtained prior to providing information to the auditor/inspector)
- Internal Audits & Supplier Audits (other than procedure and schedule)
- Emails or documents marked confidential, proprietary or privileged
Prep List (where applicable)
| List | Person Responsable |
|---|---|
| Opening Meeting Presentation | |
| Training Records | |
| Current Organizational Charts | |
| List of SOPs for EHS | |
| Regulatory Permits | |
| Air Permit | |
| Storm Water (SWPPP) | |
| Waste Water | |
| Other | |
| Hazardous Waste Manifests | |
| Industrial Hygiene Monitoring Records | |
| Employee Statement Forms | |
| Monitoring Equipment Records | |
| Employee Medical Records | |
| Employee Notification Letters | |
| Records in Lighthouse | |
| Set up SharePoint Site |
Audit Rooms
An Audit Inspection Room and Audit Prep Room will be designated. The rooms will be rearranged to support an inspection as required (copiers moved, furniture moved, supplies set out etc).
Walk Through
As identified in table below personnel will walk the floor informing affected personnel of the inspection and reviewing areas for compliance. When possible define the path of travel with the auditor/inspector. Take the most direct route to and from the location to be visited. This list can be expanded based on the activities conducted onsite.
| Inspection Areas | Person Responsible |
| Exterior | |
| Warehouse | |
| Loading Docks | |
| Utility Areas (i.e. boilers rooms, mechanical room, maintenance shop, pump house) | |
| Manufacturing Areas | |
| Construction Areas (if applicable) | |
| Infirmary/First-Aid | |
| Roof | |
| Other (please specify) |
Facility Overview Presentation
The EHS Manager and Plant Manager will create the facility overview presentation. The presentation should be rehearsed on a periodic basis with backups identified.
The following would attend the Facility Overview Presentation (Opening Meeting):
| Area/Function | Personnel | Title |
| Senior Management | ||
| CI Management | ||
| Manufacturing | ||
| Human Resources | ||
| EHS | ||
| Facilities | ||
| Engineering |
3.0 Communication
Inspection Notification List
The following on-site personnel must be notified immediately when an auditor/inspector arrives at the facility.
| Person | Office Number | Cell Phone Number |
|---|---|---|
The following off-site support personnel shall be notified in a timely manner when an inspector arrives.
| Person | Support Area | Call | |
|---|---|---|---|
| Dana Zbyszynski | Global Director EHS | dzbyszynski@justrite.com | 1-224-461-0020 |
| EHS Manager | |||
| Ben Walczak | Corporate Lawyer | bwalczak@justrite.com | 1-224-754-4857 |
| GM/VP of Business |
Facility Tour
Depending on the type of audit being conducted, below are the tour areas to be visited for the applicable audit. Always take the most direct and safest route to the area requested. Ensure required protective gear is provided and worn in areas that require it (i.e. safety shoes, safety glass, hearing protection).
| Primary | Tour Support / Backup | |
| Tour guide |
5.0 Inspection Support Team
Roles and Responsibilities
| Responsibility | |||
|---|---|---|---|
| Role: | Responsibilities: | Primary | Secondary |
| Inspection Coordinator | Responsible for the overall: * Coordination of the audit, data flow and inspection management. * Ensuring that issues are proceeding in a professional controlled manner. | ||
| Escorts | * Accompany the auditors/inspectors while they are on the premises. * Document questions the auditors/investigators may have during their tour. * The escort does not leave the inspection room. | ||
| Scribe/Requestor | Scribes will utilize SharePoint and Microsoft and are responsible for documenting the: * questions asked by the auditor/investigator. * answers provided by Justrite personnel. * general flow/direction of the audit. * Submitting document request. | ||
| System Owners | Person responsible for EHS activities and can respond to questions from auditors/investigators in a professional manner. | ||
| Prep Room Lead | * Produce the information or people being requested by the auditor/investigator. * Ensure status of requests are current. Assigns requests as needed. * Ensure that duplicate copies of any document kept by the auditor/investigator are maintained in the inspection file. | ||
| Reviewer | * Assigns requests to self as needed to fulfill the request. * Reviewers assure documents being delivered to the auditors/inspectors are the right documents and that Good Documentation Practices (GDP) are intact. * If any issues are identified the reviewer alerts the Prep Room Lead prior to the document entering the inspection room. | ||
| Copy / Stamp Person: | * Make multiple copies of requested documents and stamp documents as required. | ||
| Runners | * Deliver requested documents to inspection room. * Retrieves document(s) from inspection room, closes request and files returned documents. | ||
| Photos | * When permission is granted from the facility, the plant escort should take the picture and transmit to the auditors/inspector. * If auditor/inspector takes their own photo, the same photo shall be taken by the escort or other team member present | ||
| Wastewater, Stormwater, industrial Hygiene, etc. Sample(s) | * Split samples should allows be taken and held or analyzed. |
6.0 Subject Matter Experts / System Owners
| System(s) | Subject Matter Expert (SME) | Alternate SME |
7.0 Inspection Activities
| Responsibility | ||
|---|---|---|
| Action: | Primary | Secondary |
| Notify on-site personnel that and inspector has arrived | ||
| Notify Off-Site Support | ||
| Set up Facility Overview presentation in designated conference room. | ||
| Mobilize Opening Meeting Team | ||
| Facility Tour teams are deployed | ||
| Notify Support Team listed in table | ||
| Verify documentation from the Inspector(s) | ||
| Escort Inspector(s) into HR Conference room for discussion of purpose of audit, area of focus, expectations, etc. | ||
| **********At this point, no more than 30 minutes has elapsed. ************ | ||
| Present Facility Overview Presentation | ||
| Unannounced Inspection - During the Facility Overview presentation all inspection rooms, personnel, and equipment are to be set up, computers running with SharePoint (About 20 minutes) | Support Team | |
| Announced Inspection – Inspections rooms are set up the day before | ||
| Facility Tour takes place (as requested) | Tour Team | |
| Coordinate for lunch for support team members. |
Document and information management flow
End of Day Checklist
| Action: | Responsible |
| Ask inspector/auditor if there are any observations or concerns. Ask for schedule if not received. Request a close out meeting. | Escorts |
| Review overall performance of the support team | Inspection Coordinator |
| Review overall performance of technical experts and attitudes of auditors/inspectors | Inspection Coordinator |
| Discuss any potential observations and plans to mitigate | Inspection Coordinator |
| Review all open requests and ensure all documentation reviews are complete | Prep Room Leaders |
| Prioritize the following days agenda for each auditor/investigator | Escorts |
| Review / document lessons learned | Escorts |
| Assure that any and all requests for the next day are prepared and ready by the beginning of the next day. | Inspection Coordinator |
- Support team stays each night until all documentation requests are completed.
- Support team arrives a minimum of 30 minutes prior to auditors/inspector arrival each day.
- Escorts and Prep Room Lead meet each morning to review all open audit requests and sequence of events.
Internal Daily Wrap Up
List of attendees REQUIRED for the daily internal wrap-up (without the inspector):
| Area/Function | Personnel | Title |
| Senior Management | ||
| CI Management | ||
| Manufacturing | ||
| Human Resources | ||
| EHS | ||
| Facilities | ||
| Engineering | ||
| Audit Support Team |
Summary Report
On each day of the inspection, the Inspection Coordinator shall send an update email for the following personnel:
EHS Global Director, EHS Regional Manager, Corporate Lawyer, VP of the Business
8.0 Closing Meeting
Site management personnel shall meet at the end of the inspection. A scribe will attend to capture closing notes. Notes will be captured in a Word document to enable content review. During the closing meeting, no admission is to be made that any of the auditors’/inspectors’ observations are violations of law or deviations from regulations.
Project: Q-21699 - Saipem COMP2 Folder: HSE TBE