ADVANCEMENT OF THE PRACTICE
Open Access
THE PRACTITIONER’S TOOL KIT
The Art and Science of Inspection: Part Two
James J. Balsamo, Jr., MS, MPH, MHA, RS, CP-FS, CSP, CHMM, DEAAS Nancy Pees Coleman, MPH, PhD, RPS, RPES, DAAS
Brian Collins, MS, REHS, DLAAS Gary P. Noonan, CAPT (Retired), MPA, RS/REHS, DEAAS Robert W. Powitz, MPH, PhD, RS, CP-FS, DABFET, DLAAS Vincent J. Radke, MPH, RS, CP-FS, CPH, DLAAS Charles D. Treser, MPH, DEAAS
The compliance inspection also relies on Boolean logic (i.e., yes/no, true/false) and includes the words “and,” “or,” and “not” for the readily observable items listed in the code requirements. Due to the variability found in food, water, wastewater, and other environmental con- cerns, regulatory compliance inspections are generally designed as one-size-fits-all. This general purpose format and subjectivity rely on your professional training and expertise to evaluate the specific risks that are relevant to the facility being inspected. It is also your responsibility to a) suggest one or more com- pliance strategies that do not conflict with regulations; b) conform to good environmen- tal public health practice; and c) actively pro- mote the prevention of communicable dis- eases, injuries, or other public health-related misadventures. As with any prescriptive format, there are exceptional circumstances and conditions that depart from the inspection and justify addi- tional actions. These circumstances and con- ditions bring us to the multimedia inspection. The U.S. Environmental Protection Agency (2000) developed the multimedia inspection process to meet its objective of comprehensive compliance. This model works particularly well when health or safety issues are not part of the routine inspection, or where observable conditions depart from items on the inspec- tion form or are outside our area of exper- tise. Using retail food establishments as an example, we often see older facilities that have changed equipment, processes, and construc- tion. Examples of these are numerous saddle clamps on water supply and drain lines; ret- rofitting or changing the plumbing system to
Editor’s Note: The National Environmental Health Association (NEHA) strives to provide relevant and useful information for environmental health practitioners. In a recent membership survey, we heard your request for information in the Journal that is more applicable to your daily work. We listened and are pleased to feature this column from a cadre of environmental health luminaries with over 300 years of combined experience in the environmental health field. This group will share their tricks of the trade to help you create a tool kit of resources for your daily work. The conclusions of this column are those of the authors and do not necessarily represent the ocial position of NEHA, nor does it imply endorsement of any products, services, or resources mentioned.
I n the November 2023 issue of the Jour- nal of Environmental Health (Balsamo et al., 2023), we introduced the art and sci- ence of inspection. Inspection is an activity we all engage in. In that column, we covered the basics of inspection processes, including understanding the goals and objectives of in- spections. We also oered suggestions about the language used in the inspection report to avoid the pitfalls of misinterpretation of observations or to question the scope of the proposed corrective measures needed. We also promised that we would follow up with additional information that you may find useful in your environmental health practice, whether in the regulatory or private industry arenas. In this column, we provide a brief overview of the types of inspections and where and when they are appropriate. We promise to suggest rules of deportment (i.e., the skill expected of a professional) for the inspection process in a future column.
Here are the four basic inspection types: regulatory and multimedia compliance, audit- ing, forensic, and evaluation. Each one has its place as an important skill in our tool kits.
Regulatory and Multimedia Compliance
As governmental public health professionals, we are most familiar with regulatory compli- ance inspections. Regardless of the circum- stances or conditions that prompted an inspec- tion (e.g., routine, follow-up, response to a complaint), they all maintain a similar format. The regulatory compliance inspection is very prescriptive, broad-based, straightfor- ward, and formal in structure. The inspec- tion format uses both objective (i.e., factual, measurable, or observable data and observa- tions) and subjective criteria (i.e., data that come from feelings, experiences, opinions, and thoughts), which is highly ecient in understanding the subject of the inspection.
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Volume 86 • Number 8
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