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What to do when the DOT Inspector Arrives at Your Door!

October 29th, 2019 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

Before an inspection, all companies should establish procedures for dealing with visits by a regulatory inspector. These procedures should address a policy on taking pictures and/or recording interviews in the facility as well as security requirements. Inspections are random and unannounced. An important step in the procedure is to establish a primary and alternate contact to be responsible for interacting with any hazardous materials inspector. The primary contact should be aware of all applicable hazardous materials regulations, know where appropriate documents, such as training materials, are stored, and is knowledgeable about the basic requirements of an inspection. Important procedures to have in place include:

  1. Store applicable training certificates/materials in an easily accessible location: Evidence of training is often looked at during an inspection. Make sure that that everyone who signs shipping papers has a corresponding training record.
  2. Store applicable shipping documents in an easily accessible location: Shipping documents are often referenced and analyzed during an inspection. It is important to note that regulatory agencies only require the review of shipping papers from a certain timeframe. Any shipping documents retained beyond that timeframe should be kept in a separate location.
  3. Keep non-dangerous goods shipping documents separate from dangerous goods shipping documents.
  4. Keep any applicable regulatory manuals at the company shipping desk. These manuals should be the most current version of the regulations.
  5. Have a designated location/isle within your facility or warehouse where hazardous materials are stored. Many inspectors will want to look at how hazardous materials are stored, packaged, labeled, marked and otherwise handled prior to transport. Having these materials in a central location helps streamline the inspection process.

When an inspector arrives, it is important that the primary contact stays with the inspector as much as possible throughout the visit. The primary contact should make sure to do the following:

  1. Invite the inspector to a conference room or private office.
  2. Identify the inspector: Ask to see credentials. Write down relevant information.
  3. Determine the scope of the inspection. Ask the inspector what initiated the inspection.
  4. Advise the companies’ legal counsel of the presence of the inspector.
  5. Take notes on what is seen, what is said, by whom, and whether any samples or copies of documents are taken.
  6. When in doubt on any question posed by the inspector, do not answer. Communicate to the inspector that you do not understand the question, and ask the inspector to put the question in writing, addressed to you company counsel or designated contact. Provide them with the companies’ counsel information.
  7. Do not admit to any violation or lack of compliance verbally or in writing. Do not sign anything other than an acknowledgement that the inspector was there.
  8. Prepare a memo as soon as the inspector leaves. It should include all relevant details of the inspection, copies of documents produced or requested, etc.

At the end of the inspection, the officer will give you details regarding the outcome of the inspection and suggestions of how the company can address concerns that were highlighted.
This is normally a very fair process that helps UN shippers comply with regulatory aspects of their shipments.

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