How to prepare for a PIP inspection?
How to prepare for an inspection, and above all, how to document the employer’s actions in order not to expose the company to the severe consequences of a PIP inspection?
As the National Labour Inspectorate points out, recent changes in labour regulations may lead to abuse, hence the need to carry out control activities also in the area of payment of remuneration after reduction of working hours/transition to remote working, amount of severance pay or provision of leave. First of all, the employer should remember that PIP inspectors are entitled to carry out such inspections without prior notice, basically at any time of day or night, and they should always present their ID card and relevant authorization. Of course it happens that the employer will be informed about the date and scope of the PIP inspection – usually in situations where such information does not affect the course of the inspection. However, in such a case, the employer’s role is to prepare full documentation indicated in the correspondence, also in cooperation with the employees responsible for particular controlled areas.
In light of recent changes – i.e., the qualification of SARS-COV-2 to the third group of biological hazards for workers – we can expect more intensive inspections in the area of ensuring an adequate level of health and safety for workers, as well as providing measures to protect against the spread of coronavirus. Inspectors may therefore focus in particular on updated risk assessments for the coronavirus agent, the list of work and the register of workers exposed to this agent, introduced procedures to prevent infection, as well as procedures related to the introduction of remote working.
How to prepare for the PIP inspection?
You should be prepared to present any indicated place in the workplace and any indicated document, also from previous years.
As far as documentation is concerned, the inspectors most often visit selected workplaces during OSH inspections and review employee documentation – employee files, work regulations and salaries. Another important area is the broadly understood safety documentation – especially in the context of legislative solutions imposing new obligations on the workplace – which consists of e.g:
– Instructions and procedures,
– Professional risk assessments,
– Protocols for the investigation of the causes and circumstances of accidents at work and accident cards,
– Documentation of particularly hazardous work,
– Documentation of machinery and equipment in terms of their safe use by employees (certificates of conformity, instructions, inspections and maintenance).
You should be prepared to show any place in the workplace and any document, including those from previous years. However – also during the conduct of activities by inspectors – we must remember to observe the rules of safety. The employer is obliged to present them, and the inspectors are obliged to comply with them. It is also necessary to make available a separate place for the needs of the inspectors, enabling free familiarization with the documentation.
Inspections during a pandemic can also take place remotely, which will involve handing over designated documentation to the inspector, which can be quarantined for 24 hours at a PIP unit. However, in order to carry out inspections efficiently, documents can also be handed over in electronic form. Moreover, the Chief Labour Inspector and the Chief Sanitary Inspector currently recommend that, whenever possible, the inspector should contact the company’s representative to discuss the manner and scope of the inspection.