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Procedures For Handling an Inspection By Regulatory Agency in the Workplace

By Edited Jul 5, 2016 0 0

All employees should know how to handle an inspection or visit by a government agency.

Having the procedures in place will help calm nerves that might be experienced by employees when a government agency enters the workplace.  Training is important for all employees so they are in compliance at all times when handling an inspection or visit.

The following is a sample of the procedures that should be followed.  This sample plan can be adopted to fit the needs of your warehouse, especially in the produce industry:

Receptionist/First Contact

If you are alerted to the presence of a representative of any FDA, State or Federal Agency, immediately locate the representative and accompany them to the reception area upstairs. 

Ask them to please wait while you contact (the owner of the business, adminstrators, and the  warehouse manager).  Have them sign in on the visitors log and give them a "A visitor badge" to wear during their visit.  Ask them to please return after the visit to return the badge and to sign out.

 Warehouse Manager

 Meet with the representative as quickly as possible.  It is not acceptable to keep them waiting.

Greet the inspector, confirm his/her identity, request and accept the "Authorization to Inspect" form, if one is given, and determine the reason for the visit.  If an inspection is to take place, determine the type of inspection (limited, comprehensive, etc.) prior to beginning the inspection tour.

Discuss and clarify up front during the pre-inspection conference whether or not photographs and  review of records (other than bills of lading from plant into intrastate commerce) will be allowed. 

Be certain that the inspector has been provided the required protective and sanitation gear and equipment that is required to be worn in your warehouse prior to beginning the inspection tour.  Explain how and why you follow certain safety standards.

Accompany the inspector during his/her visit.  If more than one person is to accompany the inspector decide before-hand who will speak on behalf of the company.  The other persons will be a designated record keeper and witness to the conversations between the inspector and manager. 

Do not guide the inspector, but rather accompany him/her wherever they wish to tour.

Be courteous and businesslike.  Questions should be answered as simply as possible without volunteering any more information than necessary. 

The accompanying individual(s) should take detailed notes of the inspection and rewrite these notes following each day of a multi-day inspection.  The notes should describe the inspection as thoroughly as possible (areas inspected and the amounts of time spent there should be included.)  List the questions asked by the inspector and the replies to these same questions.  Also, anything suggesting the inspector's special inspection interests, etc.

The accompanying individual(s) should take duplicate samples and photographs of any material(s) sampled a photographed by the inspector.  A written receipt for the sample(s) with an exact description (product, size, weight, label or brand, total number, etc.) of each sample(s) collected should be obtained.  Duplicate sample(s) should be analyzed for the same conditions or organisms as the agency sample(s).         

Attempt to determine which areas the inspector intends to inspect during subsequent days, and then advise the General Manager. 

If any deficiencies can be corrected on the spot, or during the course of the inspection, take immediate action.  Immediate corrections will reflect very favorably on the company. 

Samples taken by the inspector should be split with you, or duplicate samples should be taken and properly labeled.  Analysis and proper handling of the sample will depend on the type of sample taken, and the object contaminated.

The inspector will present a "Report of Observations "at the conclusion of his/her inspection only if they not discrepancies or potential avenues of contamination. 

Inspectors will rarely offer advice or relate how competitors may have solved similar problems.  They will not enter into lengthy disagreements or discussions once an observation has been written.

Post Inspection

The post inspection conference should allow enough time to discuss the inspection and to prepare notes for a subsequent letter to the inspecting agency addressing all of the items listed on the "Report of Observations."  Also, express thanks to the inspecting agency for the inspection and for making you aware of the items requiring correction or attention.  Other than any obvious error in fact, it is generally best not to argue with either the inspector(s) or the inspecting agency.  Try to list realistic dates of correction if structural modifications are necessary.  The letter, the inspector's Report of Observations, and corrections should be reviewed for planning and response, so schedule a meeting with the General Manager as well as any plant foremen or supervisors as you feel should attend.  This meeting should follow the inspection as closely as is possible.

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