If for any reason at any time an EPA inspection is sprung on you and your facility—and you should expect anywhere from zero to some notice—you should always be ready. Naturally, keeping your facility’s operations and procedures up to snuff is the best way; still, how you respond to the inspection can have a substantial bearing on the results despite your actual status. So, here’s a bit of a “cheat” sheet to make sure you pass inspection with flying colors.
Know the Questions so You’ll Know the Answers
An inspection will typically begin with Q&A sessions involving your environmental, operational and maintenance personnel in order to preface a deeper look into your operations. Have these environmental and safety program questions answered ahead of time and you can head off any potential problems and future fines:
- How is compliance monitored and by whom?
- How are regulatory requirements specified and communicated to staff?
- How is noncompliance communicated to management?
- What is the effectiveness of the internal communication systems, particularly regarding accidental emission incidents?
- Is environmental and safety compliance factored into job performance evaluations?
- What is the status and breadth of…
- detailed process flow charts and mass balances?
- an environmental and safety training program?
- the facility’s environmental management system?
Your Inspector and You: Be Smooth and You won’t Lose
Okay, it’s the day: the inspector is here, the Q&A has taken place and it’s time for the actual inspection. Here’s how you can make it go as well as possible…
Accompany and record
Your owner, operator, or workplace supervisor should go with the inspector every step, jump, slide, crawl, etc. of the way to record the inspector’s comments. While accompanying, pay particular attention to ANYTHING asked of or mentioned to employees regarding workplace health and safety, waste management practices, past incidents, feedback, etc.
Record not only verbal actions but visual: at what is the inspector looking or handling, especially when he or she records something but doesn’t offer verbal opinion. The more notes you take on WHAT the inspector says and observes, the better.
Partner and cooperate
The next most important tip is to cooperate with the inspector—noncooperation might be hint at regulatory noncompliance. Make sure the inspector knows that all unanswered questions will be answered, and unavailable resources made available—AND when.
Correct errors on the spot
If feasible and within reason (and compliance), correct regulatory problems right away if requested to do so by the inspector. Whether a malfunctioning equipment or process, spill or emission, or a violation which could cause a hazard or measure of non-compliance, acting on-the-spot goes a long way towards a top notch inspection. If parts of your machinery need to be lubricated, order the proper lubricants from a wholesale industrial equipment lubricant manufacturer.
Copy cat samples & records
Piggybacking on your note-taking, if the inspector takes samples of your waste stream or any other measurable form of emission, take a sample for yourself; past samples are just that—having nearly identical samples is the only way this protective measure works so that degeneration/break-down issues don’t factor in. Make sure your documentation methods corroborate your sample with the inspector’s.
Also, ask the inspector what test or analysis the sample will undergo and have the same test or analysis conducted independently on your sample.
Should the inspector request copies of records, either make them right then or set up a delivery time if the amount of copying is so substantial that immediate provision is not possible. Either way, make sure you produce a set your own records.
Picture is worth a thousand words—make that 2,000
The inspector might also take pictures of relevant plant equipment or manufacturing processes; you should take the same pictures. Be sure that your camera’s date/time stamp is updated and accurate.
First and foremost, your facility’s environmental, operational and maintenance leaders should already be on top of what’s necessary to run and maintain a legally compliant company. If not, inspections can be brutal. But if you follow this “cheat” sheet in addition to being as EPA -compliant as possible, you can be ready for anything!
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