Date: Tue, 1 Mar 2011 17:15:43 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: Photographing non-compliance
In-Reply-To: <20110301.115824.1022.0**At_Symbol_Here**>
As long as the problem is fixed, photographing should not be an issue and
may be helpful in the future as the photo, plus the other documentation,
plus documentation of the fix (including photo) can be a helpful
demonstration of good faith efforts to fix problems when found.

Of course, if the problem is not fixed, then any documentation - whether
photo or merely a text description - can be used as ammunition by a
regulator or litigant. But if that is your concern, you have better not
commit any observations of non-compliance to writing, forget about the photo

In my opinion, it is better to communicate the issue clearly with the
written word and photos or drawings where they are helpful, thereby more
likely getting the problem corrected, than, for fear of citation or
litigation, to communicate less clearly or not at all.  I don't imagine
regulators care much for "willful ignorance" in any case.

Peter Zavon, CIH
Penfield, NY



> -----Original Message-----
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] 
> On Behalf Of paracelcusbombastusvon**At_Symbol_Here**
> Sent: Tuesday, March 01, 2011 12:58 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: Re: [DCHAS-L] Photographing non-compliance
> I do it all the time as a part of all my EHS inspections of 
> all the plants I visit.  The picture is next to a written 
> description of the issue and the applicable 
> OSHA/EPA/NFPA/building code/etc regulation.  The report is 
> distributed to the plant manager, vice-president, and ceo.  
> Most appreciate the picture since it points to the issue at the time.
> Lynn K

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