The receptionist brings you the business cards of two PHMSA auditors and tells you they are waiting to speak to you. What do you do?
Well, after taking a deep breath, you go introduce yourself and find out why they are there. A “surprise audit” is how they respond, and you think, “OMG, how can this be happening?” Once you regain your senses, you ask them more about the process and what they wish to see. When they ask you questions, be honest; don’t try to hide things – that will only get you in trouble.
First question: Where are the training records?
If PHMSA feels that you are a hazmat employer, you will have hazmat employees. Under 49 CFR 172.700 you are required to train employees in general awareness, function specific, security and safety training. You are required to have documentation of that training. It is required every 3 years.
There are several possible violations: failure to train and/or failure to document the training.
A violation for training is easy to avoid. Keep good records, and ensure all employees who could be considered hazmat employees are retrained every three years – without question!
Second question: Where are your packaging records?
What packaging are you using? Do you have a packing instruction sheet for that package on file? Are you preparing it as the manufacture said you should? Did the manufacture provide you with instructions that are repeatable time after time? Are you following the closing instructions? Are you torqueing the bottles as you should? PHMSA will ask to see everything, including the torque wrench that you are using.
At the end of the day, PHMSA will sits down and explain what they find. If you are lucky, you will have no probable violations, and perhaps some recommendations. If you are not so lucky, PHMSA will explain the probable violations, and the process for the corrective actions.
Corrective actions are very important. Your response to the corrective action may determine how bad your actual violation maybe in the end. If you have probable violations, spend time ensuring that the corrective actions are well thought out meet the 49 CFR standards and correctly respond to the violation.
What starts out as a stressful day turns out to be a valuable learning experience. If you are doing things right to begin with, PHMSA will understand that, and will work with you to fix about problems.
Did you know that ICC has auditing services? Let our regulatory experts come and audit your operation, including training and packaging records. We will provide a list of “probable violations” and feedback that you can use to improve. You never know when you will have that knock on the door.