With today’s intense focus on regulatory compliance and environmental regulations, it’s standard practice to find yourself dealing with federal inspections. Sometimes these inspections will be a surprise. The Environmental Protection Agency (EPA) might show up unexpectedly and ask to tour your facility, review monitoring data, and interview employees. Now, most companies have longstanding and respectful relationships with state and federal regulators, and certainly never intend to be uncooperative or evasive. A lack of preparation, however, can suggest otherwise. Perhaps not surprisingly, preparation for a surprise inspection is much more important than the proper response to one, and should be treated accordingly.
Here are some essential points for consideration:
1.) Make sure your emergency information is accurate and up to date.
This may be one of the first things an inspector delves into upon arrival at your facility.
2.) Keep your Main Accumulation Area (MAA) maintained and compliant, and your weekly MAA inspection logs complete and up to date.
Deficiencies during this portion of an EPA inspection will most likely lead to a higher level of scrutiny during the remainder of the inspection. Be sure that you are completely in compliance with MAA regulations and that the space is as clean and organized as possible.
3.) Train and prepare all relevant personnel and staff ahead of time.
On-site, an inspector will most likely “interview” staff. Questions might focus on hazardous waste management, safety procedures, or even chemical compatibility issues in your chemical storage cabinets.
Staff members should begin every inspection with a request to view the inspectors’ official agency credentials and copies of business cards that identify each inspector, job title, and affiliation. They can also use this opportunity to ask questions, try to determine what prompted the inspection, and understand its nature and scope.
RCRA compliance is all about records. Be sure that all training records and Standard Operating Procedures (SOPs) are readily available.
Don’t underestimate the value of a professional and courteous demeanor.
4.) Conduct a mock inspection.
Nothing helps to prepare a facility like a mock inspection – conducted under the direction of legal counsel. It is far better to flag the tough questions in advance than to face them for the first time during an inspection. A mock inspection will help identify if permits, approvals, or other documents required to be maintained on-site and available for inspection are accessible, clearly labeled, and well organized.
5.) Always treat inspectors like ordinary visitors, and offer basic safety training before walking the site.
When all is said and done, it’s time for a thorough self-evaluation. Far too often, a facility will wait until the EPA gives them formal notification of a problem. This is a mistake. If you’re aware of problems, correct them. If something couldn’t be located, locate it. If a drum was uncovered, cover it.
If the EPA follows up on an unannounced inspection, finds a violation, and then learns the violation has not been corrected, that violation is likely to result in EPA violation penalties. Solid preparation for EPA inspections will bring you peace of mind, and dramatically increase your chance of success when one finally comes about. Do yourself and your business a favor and do something about it now. For more information on EPA regulations and compliance, you can link to the official website of the Environmental Protection Agency: EPA
Hazardous Waste Experts is available to assist you in ensuring that your environmental program is fully compliant. For expert guidance on regulatory compliance, environmental permits, emergency response plans, hazardous waste training, and more. Our experts can help you navigate the complexities of hazardous waste management and meet the requirements of hazardous waste disposal regulations. Don’t overlook the importance of inspection documentation and maintaining a high level of environmental program compliance. Call us at 800-936-2311 or click here to email us.