FOX Environmental, Health & Safety

FOX Environmental, Health & Safety

FOX Environmental, Health & Safety > EHS 004 – Regulatory Agency Inspections

EHS 004 – Regulatory Agency Inspections

FOX Corporation will comply as required with any regulatory agency inspection at any location under its control.

1.0 SCOPE

This procedure specifies the procedures to be followed in the event of a regulatory agency inspection at any location under the control of Fox Networks
Group (FOX) and addresses procedures to be followed to ensure that FOX’s legal rights and obligations are upheld.

2.0 Definitions

None.

3.0 Responsibilities

In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS001, EHS Policy, the responsibilities described
below are necessary to ensure the effectiveness of the procedure.

Security personnel assigned to FOX locations will:

  1. Request to see identification from any person who identifies his/her self as a regulatory officer.
  2. Detain the regulatory officer(s) at the site entrance until the appropriate official for the location being visited can arrive.
  3. Notify the appropriate FOX management contact to meet and escort the regulatory officer(s).
  4. If possible, contact the FOX Environmental, Health and Safety (EHS) Department at 310.369.2671 or by contacting Fox Security at 310.369.6555, which
    will then contact an EHS Department representative.

3.2 Division Heads

Division Heads will:

  1. Ensure that division-level personnel are aware of the requirements in this Procedure.
  2. Support and participate in all regulatory agency investigations as warranted or required.
  3. Ensure adequate funds are allocated at the division or department-level to ensure effective resolution of regulatory agency findings, citations, or
    violations.

3.3 Department Heads

Department Heads will:

  1. Notifying the EHS Department immediately upon receiving notice of planned or no-notice inspections of their affected workplaces or locations.
  2. Ensure assigned managers and supervisors cooperate with all regulatory agency personnel.

3.4 Supervisors and Employees

All supervisors and employees will:

  1. Support and participate in all regulatory agency investigations as warranted or required.
  2. Notifying the Department Heads immediately upon receiving notice of planned or no-notice inspections of their affected workplaces or locations.

The EHS Department will:

  1. At the Fox Studios Lot:

a. Meet with regulatory officer(s) when they arrive on site and participate in the opening conference.

b. Escort the regulatory officer(s) while on the facility.

c. Note all findings observed by the regulatory officer(s).

d. Participate in the closing conference.

  1. At other FOX locations:

a. Participate in the opening and closing conferences by telephone (if possible).

b. Discuss the regulatory officer(s) activities while on site with the escort.

  1. Serve as the contact with the regulatory agency in responding to any findings or citations.
  2. Publish and periodically review and revise the policy on regulatory agency inspections.

4.0 Procedure

4.1 Initial Contact

Security officers will be the first Fox personnel to meet any regulatory officer visiting a Fox site. Once the regulatory officer presents his/her
credentials and requests access, the security officer will ask the regulatory officer to wait and will contact:

Fox Studios Lot
FOX EHS Department.

Normal business hours: ext. 3-2671 or 310.369.2671

Other FOX Locations
Applicable Department Heads or location management.

The regulatory agency representative must wait to be escorted by the appropriate FOX management Representative. Under no circumstances are regulatory
officers to be granted access to an FOX location except under escort from designated FOX management personnel.

4.2 Regulatory Agency Inspection Procedure

A representative of the EHS Department or applicable FOX management will meet the regulatory officer(s) at the site entry:

  1. Verification will be made that the person(s) is an authorized regulatory agency compliance officer.
  2. Determination of the nature of the site visit (e.g., routine inspection, specific complaint, report of injury, etc.), and intended extent of the
    area(s) to be visited will be made.
  3. The regulatory officer(s) will be accompanied throughout the site visit, FOX personnel taking detailed notes and photographs of all actions and
    findings noted, personnel interviewed, etc. This should include:
  • Area(s) visited
  • Employees and other persons interviewed
  • Employees’ use of personal protective equipment
  • Machines/equipment/process/activity inspected
  • Material examined
  • Potential safety and/or health hazards inspected
  • Samples taken.

At a minimum, photographs are to be identical to or a least taken from the same angle (or as close to it as possible) as those taken by the regulatory
officer. Also, careful notes are to be taken in sufficient detail about the area(s) photographed.

  1. If any exposure assessment measurements or environmental samples are collected duplicate sampling should be performed by FOX, where possible. If
    duplicate sampling is not possible, the following information will be noted:
  • The contaminant sampled
  • The number of samples taken and when each was taken
  • The types of equipment used to take samples
  • How often sampling equipment is checked.

If the regulatory officer takes environmental samples, duplicate samples are to be requested as evidence that may prove helpful in the event of citation or
litigation.

  1. Request that the regulatory officer(s) perform an outbrief at the conclusion of their work on site. Any findings or on-the-spot citations should be
    noted, but no responses given at that time.

4.3 Inspection Follow-Up Actions

4.3.1 Regulatory Notices, Violations or Citations

If regulatory notices, violations or citations associated with EHS are received following any inspection, the following actions must be taken:

1. The document shall be immediately marked with the date received and the original forwarded to the EHS Department.

2. A copy of the citation shall be posted in each work area where a violation has been cited (after the right-hand portion of the citation that refers to
the penalty has been removed).

3. The citation shall be left posted according to the applicable regulatory requirements or until the violation has been corrected, whichever is longer.

4. All response actions and investigations will be managed by the EHS Department. Under no circumstances will any other FOX department or personnel
discuss/settle any regulatory citation or directly pay any associated fines or penalties.

4.3.2 Written Response to Complaints

If a regulatory agency receives a written or oral complaint, it may serve a written request upon FOX to investigate the alleged conditions and make any
necessary corrections, usually within a specified time frame. In this event, FOX must give regulators a timely written response that includes results of
the investigation of the alleged complaint. Unless otherwise directed, the EHS Department will facilitate all necessary investigations, develop responses,
and communicate them to the applicable regulatory agency.

5.0 REFERENCES

EHS001, EHS Policy.

6.0 ATTACHMENTS

None.