If you are shipping or receiving any type of dangerous goods or hazardous materials, it is likely that one day, when you are in the midst of a special project, a DOT inspector could show up at your front door. Some people believe that if this happens, you are to try to evade the inspector, say you are on vacation or just lie and say you are not there. In fact, this is the worst thing that you can do, and frankly, if you have prepared for the visit, you should be able to confidently welcome the inspector into your company. To be prepared, the Council on the Safe Transport of Hazardous Articles (COSTHA) is offering a free booklet of suggestions that will help you prepare for the visit. Before an inspection, all companies should establish and define procedures for dealing with any regulatory inspector. At a minimum, when an inspector arrives immediately do the following:
- Identify the inspector
- Make an appropriate company official responsible for interacting with the inspector
- Determine the scope of the inspection
- Advise legal counsel of the presence of the inspector
- Take notes on all conversations or record the conversations
- When in doubt on any question posed by the inspector, do not answer
- Prepare a memo to the file describing the visit, as soon as the inspector leaves, and
- Include all relevant details of the inspection, copies of documents produced or requested.
For a free copy of the booklet, click on this link to for the download.