1.5 Government Inspections and Surveys
OBJECTIVE
The objective of this program is to provide guidance for well managed government (regulatory) inspections and surveys. Planning for such occasions will ensure the process is properly managed and causes minimum disruption. It is HGST’s practice to fully cooperate with all government (regulatory) inspections and surveys.
REQUIRED PROGRAM ELEMENTS
1. Immediate notification to appropriate management and staff whenever a governmental agency conducts a health and safety inspection of our facilities or formally contacts HGST regarding an alleged regulatory violation.
• Notification at a minimum shall be made to the location human resources manager, site OHS manager, legal counsel, senior location management and the CHQ Manager of OHS.
• Within three business days of an inspection, a written report shall be submitted to the appropriate reporting chain.
2. A plan to accommodate regulatory agency inspections, including:
a. Designation of two managers (with alternates) to be contacted immediately upon arrival of a governmental compliance officer
b. Requirement that the designated manager or alternate, accompany the government representative during any inspection of the facility
c. Establishment of the notification protocol through the building receptionist
d. Ensuring the designated managers are prepared to discuss:
• The actions that location management have taken to improve the safety of the work environment
• Familiarity with the safety audit and review programs, and location, operating unit, and HGST OHS guidance materials.
e. Notification to appropriate management and staff
f. Pre-inspection meeting - to gain agreement on the parameters, special areas of interest, anticipated employee involvement, and anticipated length of time needed for the inspection
g. Documentation of any significant items noted during the inspection by the accompanying managers
• Notes to include any potential non-compliance situation, the specific standard(s) at issue, and the inspector’s estimate of a reasonable time period in which to correct the situation.
• HGST photograph the same scenes that inspector photographed.
• HGST obtains parallel samples of the same samples taken by inspector
• HGST take direct readings in parallel with the inspector’s reading whenever possible.
h. A closing conference, including:
• Identification of the inspector’s probable findings, and HGST’s position on each
• Identification of any finding which HGST feels is unreasonable.
k. Notification to appropriate management and staff of the results of the inspection
j. Written documentation to the inspector (within 48 hours) of any actions taken - as a demonstration of good faith
k. A written report within three days to appropriate management and staff, including:
i) Status of any corrective action taken
ii) Duration of the inspection.
iii) Questions/comments by the inspector
iv) Number of employees questioned
v) Recommendations received
vi) Any other pertinent information.
3. Immediate notification to appropriate management and staff upon receipt of a regulatory agency notification of proposed citation or penalty.