Coping with Environmental Agency Inspections

Before, During, and After

Jerry P. Bauer, P.E.Burns & McDonnell Engineering Company

May 2015

Agency Inspections

Environmental Inspections are like…

Taking a test

Agency Inspections

Your fate is determined (primarily) prior to the inspection (test)!

Environmental Agency Inspections

What to do…….

• Before the inspection• During the inspection

• After the inspection

Before the Inspection

► Make sure your Facility…

►Is in Compliance with ALL Environmental Requirements!!

Before the Inspection (What to do)

Develop an “Environmental Regulatory Inspections” Policy

►Define Company Policies and Procedures Associated with Managing Environmental Agency Inspections

(Guide the person in the hot seat when the inspector shows up).

Before the Inspection (What to do)

Advantages of Having Written Policy

►Quick Reference Guide (especially if regular contact is absent)

►Support Environmental Coordinator in taking hard line

► Uniform Company Position/No Second Guessing

Before the InspectionORGANIZE ENVIRONMENTAL RECORDSAdvantages of Well Organized Environmental Records

1. Able to Provide Requested Records

2. Avoid Providing too Much Information

3. Get Inspector Out the Door

4. Appearances Count

Before the Inspection

ELIMINATE LOW HANGING FRUITExample of Low Hanging Fruit

Spent Fluorescent Bulbs - ► Containers not

dated/closed.

► Obvious Universal waste

violation.

Before the Inspection

Examples of Low Hanging Fruit

► Poor Housekeeping/ Oil spill

“Bad Appearance”

Day of the InspectionQuickly Review Company Policy and…

► Verify Inspector Credentials

► Inquire about purpose of inspection/request inspector documents

►Notify (Plant manager, attorney, etc)

► Set up in dedicated conference room

► Confirm Ground Rules (No photos, escort at all times, etc.)

Day of the Inspection

Walk-Through/Plant Tour

►Show Auditor requested area (no more)►No Safety Shortcuts►Straight line to requested areas

Day of the Inspection

Inspector Interviews

► If Inspector asks to interview specific person…► If Inspector request is more general:

• Avoid the “loose cannon”• Avoid employee with axe to grind• “Cherry Picking” is ok

Day of the Inspection

Records Review

►Put Auditor in conference room (remote from records)

►Provide records requested; no more, no less

► Copy and provide requested records

Day of the Inspection

Exit Meeting

► Always a good practice!► Don’t argue “big ticket items” but correct factual mistakes► Ask for written report► Inform inspector if corrected on-site (day of inspection)

Day of the Inspection

Issues that Can Be Resolved in Exit Meeting

►Employee indicates he was not trained on SPCC/Storm Water Universal Waste (but you have sign-in sheet for the class)

►Missing Inspection Records (that you have)

►Container (Used oil) not labeled (inspector did not see)

After the Inspection► If no issues/findings…..

Congratulations!!!!!

After the InspectionIf Issues/Findings Identified….

►Consider Pro-Active Response to Audit (Before letter/Notice Of Violation Received)

►Respond to Formal Requests for Information, Letters, or NOVs

►Take Corrective Actions to Prevent Recurrence

Summary and Recommendations

1. Have a policy in place before the inspection.

2. On the day of inspection:

a. Provide records requested – no extras

b. Answer questions asked – nothing else

c. Show inspector areas requested- no more

d. Being an a**h*** never helps- and can make the situation much worse

3. Respond Promptly to Inspection reports