Inspection Communication Process
Purpose
Cornell Research Safety conducts laboratory inspections as a service and partnership to support campus researchers. Inspections identify opportunities for compliance improvements and risk reduction to protect laboratory personnel, students, support staff, the public, and the University. Research areas are subject to safety standards, regulations, and codes required by accreditation bodies and granting agencies.
Please consider Research Safety a partner and resource. Assistance is available anytime via askEHS@cornell.edu. At each step in the inspection process, Research Safety works collaboratively with stakeholders to identify barriers and solutions. For infrastructure or facilities-related issues, it is generally sufficient to submit a Facilities work order and provide the ticket number in your corrective action response.
Regulatory Foundation:
- OSHA Laboratory Standard (29 CFR 1910.1450)
- NIH Guidelines, BMBL (biosafety)
- 10 NYCRR Part 16 (radiation)
- Cornell Policies 8.6
Inspection Types and Frequency
| Type | Frequency | Scope |
|---|---|---|
| Routine Lab Safety | Annual-Biennial | General safety, chemical/biological hazards, PPE, waste, equipment |
| Radiation Safety | Semiannual-Annual | RAM inventory, contamination surveys, sealed source leak tests, x-ray equipment |
| Laser Safety | Annual | Controlled area integrity, eye protection, equipment inventory |
| Regulatory-Triggered | As Required | IBC/IACUC protocols, Select Agent facilities, field research |
| Incident Follow-Up | Event-Driven | Post-spill, exposure, near-miss, or audit finding |
Frequency may increase based on hazard complexity, compliance history, or regulatory requirements.
EHSA Platform – Your Safety Management Hub
All inspections are managed through EHSA (EHS Assessment) at https://ehsa.ehs.cornell.edu/ehsa/
Key Features:
- View all inspection findings in real-time
- Submit corrective action responses with photo documentation
- Track due dates and receive automated reminders
- Request deadline extensions with justification
- Access training status and equipment inventories
Who Can Respond:
- Principal Investigator
- Anyone listed as a "Worker" in EHSA permit records
- Lab Managers/Secondary Contacts automatically receive notifications
Need Access? Email your assigned inspector or askEHS@cornell.edu with your NetID.
The Inspection Process
1. Scheduling (1-2 Weeks Before Inspection)
Inspector contacts PI/lab manager to:
- Confirm lab locations and personnel roster
- Request updates to EHSA Worker list
- Highlight any overdue training (gives opportunity to address proactively)
- Schedule mutually convenient time
Action Item: Review and update your lab's Worker list in EHSA to ensure the right people receive notifications.
2. Inspection Walkthrough
- Collaborative process—lab personnel accompany inspector
- Real-time discussion of findings
- Immediate corrections encouraged when feasible
- Findings documented with photos in EHSA
Domains Covered:
- General Safety: PPE, signage, emergency equipment, housekeeping
- Chemical: Labeling, storage, waste, fume hood function
- Biological: Containment, decontamination, biosafety cabinet certification
- Radiation: Inventory verification, contamination surveys, postings
- Equipment: Maintenance records, calibration, safety interlocks
3. Report Delivery (Within 10 Business Days)
- Inspection report emailed to PI and designated lab contacts
- Findings categorized by severity with assigned due dates
- Link to EHSA response portal included
Responding to Findings – Your Responsibilities
Timeline
- 14 days: Target for submitting your response (not necessarily completing all work, but documenting progress or plans)
- Due Date (typically 30 days): Deadline for completing corrective actions
How to Respond
- Go to https://ehsa.ehs.cornell.edu/ehsa/overview/pioverview/piinspectionresults
- Grey header rows separate one inspection from another
- Findings requiring action display:
- Blue Respond button
- Due Date in the first column
- Pink highlight if overdue
- Click Respond → Enter detailed description of corrective action taken
- Attach photos showing completed work (before/after images helpful)
- Click Submit to Inspector
Note: Provide enough detail for EHS staff to confirm the corrective action was responsive to the finding without requiring a follow-up site visit.
Response Quality – What Inspectors Need
| Good Response | Insufficient Response |
|---|---|
| "Replaced expired fire extinguisher in Room 101; new unit installed 12/5/24, inspection tag attached; old unit returned to EHS warehouse (disposal ticket #12345)" | "Fixed" |
| "Updated HASP emergency contact list to reflect current personnel; new sign posted 12/6/24 (photo attached); distributed updated list to all lab members via email" | "Updated sign" |
| "Submitted Facilities work order #67890 on 12/3/24 for fume hood alarm repair; expected completion 1/15/25 per F&CS estimate" | "Working on it" |
Requesting Deadline Extensions
When to Request:
- Equipment vendor lead times exceed deadline
- Facilities work order awaiting approval/scheduling
- Budget constraints require capital request approval
- Personnel turnover creates temporary gaps
How to Request:
- Use Respond button and explain barrier + realistic timeline
- Email inspector directly (contact info in report)
- Contact askEHS@cornell.edu
Justification Required: Explain specific obstacle and steps taken to address (e.g., "Vendor lead time 45 days; order placed on this date, expected delivery that date")
Extensions typically granted for legitimate resource/timeline constraints; denied for lack of progress or non-responsiveness.
Escalation Process – What Happens with Overdue Items
Weekly College Safety Representative Reports: All open findings are reported weekly to College Safety Representatives (CSRs) and Department Safety Representatives (DSRs) to enable local assistance with resolution.
Formal Escalation Timeline:
| Timing | Action | Who Gets Notified |
|---|---|---|
| 7 days before due date | Automated reminder email | PI, lab personnel |
| At due date (typically 14 days after inspection) | Direct contact from EHS inspector | PI, DSR, CSR, department/administrative manager (as appropriate) |
| 30 days overdue | Monthly report to Department Chair; includes any elevated-risk findings from last 3 months (even if already resolved) | PI, Department Chair, DSR, CSR |
| 90 days overdue | Quarterly summary to Dean | PI, Department Chair, Dean, DSR, CSR |
| Persistent noncompliance | Referral to oversight committees (IBC, IACUC, IRB, RSC); potential research holds, permit restrictions, grant certification impacts | PI, Chair, Dean, OVPR, relevant committees |
Imminent Hazards: University Safety Officer has authority to take immediate corrective action (including lab closure) per Policy 8.5 for severe hazards, bypassing standard escalation timelines.
Follow-Up Inspections: Research Safety may conduct follow-up site visits to verify corrective actions, particularly for high-risk findings or complex infrastructure corrections.
Support Resources
Research Safety operates as a proactive partner. If you're experiencing challenges with corrective actions:
| Resource | When to Use | Contact |
|---|---|---|
| Assigned Inspector | Technical questions, feasibility discussions, clarification | Direct contact info in inspection report |
| askEHS@cornell.edu | General safety questions, system access issues | Email helpdesk (24-48 hour response) |
| SME Consultation | Complex hazard controls (BSC placement, shielding calculations, ventilation) | Request via inspector or askEHS |
| Facilities Services | Infrastructure-related findings (fume hoods, eyewashes, door hardware) | Submit work order; provide ticket # in EHSA response |
| EHS Training | Training requirements, custom courses | Contact via askEHS |
Proactive Engagement Encouraged: Contact Research Safety before inspections to discuss anticipated findings or compliance concerns. Early consultation identifies simpler solutions.
Consequences of Unresolved Findings
| Consequence | Impact |
|---|---|
| Loss of Research Authorization | Protocol suspension; cannot initiate new experiments with regulated materials |
| Grant Certification Restrictions | OSP may withhold new grant certifications pending correction |
| External Audit Citations | OSHA/NIH/CDC penalties ($7,000-$15,000 per violation); reputational harm |
| Increased Inspection Frequency | Shift from biennial to annual/quarterly inspections |
| Mandatory Remedial Training | Required courses or one-on-one coaching for knowledge gaps |
Risk Mitigation Philosophy: Research Safety escalates reluctantly and only when collaborative resolution fails. The goal is closure, not punishment—but regulatory accountability cannot be waived.
Five Principles for Successful Inspections
- Engage Proactively: Check your EHSA portal regularly; don't wait for reminders
- Respond Promptly: 14-day response target reduces escalation risk
- Document Thoroughly: Photos and detailed descriptions enable faster closure
- Request Extensions Early: Communicate barriers before items become overdue
- Leverage Support: Research Safety helps solve problems—ask for assistance
EHSA Quick Reference
Common Access Issues:
| Problem | Solution |
|---|---|
| Cannot see findings | Email askEHS@cornell.edu to request Worker role assignment |
| Respond button missing | Finding already submitted/approved; check status |
| Cannot upload photos | Resize to <5MB or convert to .jpg/.png |
| Login fails | Use Cornell SSO troubleshooting: https://it.cornell.edu/sso-support |
Help Resources:
- Built-in Help button in EHSA
- Video tutorial: "Responding to Safety Review Findings" (Workday Learning)
- Monthly office hours: First Thursday, 2-3pm (link in EHS newsletter)
Contact Information
- General Questions: askEHS@cornell.edu
- System Support: askEHS@cornell.edu
- Inspector Contact: Provided in inspection report
- PI Inspection Portal: https://ehsa.ehs.cornell.edu/ehsa/overview/pioverview/piinspectionresults
Questions or feedback on this process? Contact Research Safety leadership via askEHS@cornell.edu.