Goals to Ensure Inspections are Accurate, Repeatable, and Fair
1. e;elo6 ( 6re+0*90;e mo+el 9o e;(lu(9e 6o9e490(l r0818 9o 9/e /e(l9/ o- 9/e 6ubl0*
2. (9/er em60r0*(l e;0+e4*e 3. &e0./ (4+ ;er0-> A4+04.8
4. 4(l>?e 9/e re8ul98 (4+ +e;elo6 ( re(l0890* <or1(ble (4+ *o4808 - 9e49 (b(9eme49 6l(4 or 6l(4 -or 0m6ro;eme49
Image © Adobe Stock: auremar.
committing false positive conclusions, and thereby compromising your credibility. The second goal of an inspection is gather- ing empirical evidence, which translates into sampling and instrumentation. Sampling is an art unto itself—to sample without contami- nation or introducing bias ensures accuracy and fairness. The sampling process should be repeatable and the sample itself should be a representative part of a larger whole or group, especially when presented for inspection or shown as evidence of quality. Consider using a simple random or stratified sampling strategy. But more on this topic in a future article (and also check out our column on practical field sampling strategies in the April 2023 Journal , www.neha.org/Images/resources/JEH4.23-Col umn-Practitioners-Tool-Kit.pdf). The other half of gathering empirical evi- dence is the proper use of field instruments. At the very least, read the manufacturers’ instructions and be aware of the instru- ment’s limitations, response time, readout, and interpretation of data. Calibrate or vali- date the instrument’s accuracy before going into the field and check the adequacy of the instrument’s power source. Most impor- tantly, protect all field instruments against temperature and other physical extremes (e.g., a hot car, damage, contamination) by transporting them in a clean, insulated car- rier, and maintain all field instruments in a well-maintained and presentable condition. Remember, improper use and maintenance of sampling tools and poor sampling strat- egies do not serve the objectives and pur- poses of the inspection.
The third goal of an inspection is weigh- ing and verifying findings. We achieve this goal by creating a risk prediction model. The risk prediction model combines informa- tion about past events, as well as observed changes in conditions or circumstances. Together with these current observations, these data make predictions about future events. This practice is the basis for disease and injury prevention strategies. The data used in the risk prediction model come from your observations, your sampling acumen, and your proper use of field instrumentation. The inspection should be so structured that it is repeatable when done by a colleague. The fourth goal of an inspection is ana- lyzing the results and developing a realistic, workable, and consistent abatement plan or plan for improvement. Remember, you are the expert. It is your responsibility to translate the findings of the inspection in such a way that it is understandable to the client. Objectivity will allow the client to explore dierent pathways to compliance. Therefore, the final outcome of an environmental health inspection is preven- tion, where the preventive eorts become part of the client’s normal operations. Whether you use a paper inspection form or a computer program, the language used to detail your findings can make for ease of compliance, rather than having the client guess at an outcome. As you well know, the inspection process consists of both closed- ended and open-ended requirements. These requirements determine how decisions on abatement or improvement become part of the client’s operations. In describing a viola-
tion, the most important consideration is the language we use to communicate the regu- latory expectation. Closed-ended require- ments are very objective, prescriptive, and specific. For example, “Water and ice from an approved source,” where “approved source” already has a regulatory definition. On the other hand, open-ended requirements pro- vide the maximum flexibility in interpreta- tion and can (and often are) quite subjective. An example is, “Physical facilities installed, maintained, and clean.” What does this state- ment even mean? If we cite an open-ended requirement, we have the obligation to pro- vide specific language to clarify the intent of the regulation and compliance expectations beyond that written into the regulation. And we need to do so to resolve the dierences between expected and planned results. To gain consensus between the inspector and the inspected, avoid using open-ended words and phrases such as timely, promptly, and ongoing without agreement and clarifi- cation. Generalized or broad statements such as control or manage can apply to everything. Be specific. Do not use unclear or undefined words such as suitable, adequate, and exercise care. Each one of us evaluates these words and phrases in generalities based on our life and work experiences. We are all dierent, as are our interpretations. Do not use words that lack verifiable actions or outputs or provide no pre- scriptive requirements, such as clean and safe, without asking for desired objective outcomes. As a final admonishment, never use emo- tional words and phrases. These include words that could create the appearance of
43
November 2023 • our4(l o- 4;0ro4me49(l e(l9/
Powered by FlippingBook