EHS Topic of the Month: Effective Entry Policy

Foundries should have an entry policy for admittance to their facilities to help control access to management and production areas and ensure that visitors are properly identified. This is especially important when regulatory agencies, such as OSHA, come knocking on your door. The following excerpt from the 2023 NFFS Regulatory Compliance Calendar provides information on effective entry policies and a draft template you can use for your own foundry:

Foundries should identify those individuals who are authorized to act on behalf of the owner/operator in his or her absence and provide specific guidance on the parameters of that authority. 

“Effective immediately, ABC Foundry management reserves its rights under The Occupational Safety & Health Act to be present during any inspection. No employee has authority to permit entry to any inspector or representative of a regulatory agency in the absence of the owner (designated person or persons).

If (or when) this situation arises, XXXXX will inform the inspector that no one present has the authority to grant entry and that the staff will attempt to locate the owner (designated person or persons) immediately. A request for a delay in the inspection until the owner can be located should be made to the inspector and an appointment established, if possible.

We realize that this policy may sound restrictive, but rest assured, we will fully cooperate with any and all inquiries regarding our safety program. This policy is necessary simply for the safety of all who enter this facility.”

Be certain that the person who grants entry determines:

• The reason for the inspection (complaint, targeted inspection, follow up, random).
• Is the agent a safety or health specialist?
• Is the inspection directed to a specific operation, condition, or location or does it concern the entire facility? If the inspection concerns only a department or portion of the facility, access to the remainder of the facility may be curtailed.
• In most cases, the inspection will begin with an opening interview and a review of paperwork. Be sure that you understand WHICH records, programs, materials, etc., are being requested. Too many times companies do have good programs but fail to provide the inspector with proof because of a lack of communication.