Posted on Wed, Mar 03, 2010 @ 03:10 PM
By Ian Lanza, Life Sciences Operations Coordinator
Being prepared for a state or federal environmental agency inspection can mean the difference between passing with flying colors and non-compliance. Often state and federal inspectors do not give prior notice of an inspection, or very short notice (a day or two). Today is the time to prepare your facility for an inspection!
You should have an Inspection Plan to which key institutional stakeholders have been trained. Having a plan where key stakeholders know how to immediately respond to a surprise inspection is vital. Key stakeholders include:
• The receptionist
• EH&S staff
• Department managers
• Hazardous waste generators
Receptionist
Upon arrival, the receptionist should be prepared to accept the inspector into the facility and calmly notify the other key stakeholders of the inspection. Do not allow the inspector beyond the front lobby until the EH&S manager has arrived onsite.
EH&S
Generally, the EH&S staff will accompany the inspector throughout the facility. Greet the inspector and bring him/ her to a conference room to gain a clear understanding of the purpose and objective of the inspection. Do not offer any other details which are not specifically asked for.
Department Managers
Department Managers should be notified that their areas will be inspected for environmental compliance by a state or federal agency. Employees working in these areas should be respectful and honest with any regulatory figure. I have often found that employees tend to be on their best behavior when they know there is an inspection as well.
Hazardous Waste Generators
Any employee who generates or manages hazardous waste will probably be interviewed by the inspector at the point of waste generation or collection. This is why it is important for responsible employees to have a comprehensive understanding of their role and obligations because the inspector will test them. If the inspector finds a compliance issue, the responsible employee should not get defensive, but should acknowledge the issue and correct it immediately.
Being prepared for regulatory inspections can mean the difference between passing and failing the audit. You should bring together all applicable stakeholders, train them on their role and responsibilities, and get them prepared for a surprise inspection.
Posted on Tue, Sep 15, 2009 @ 12:50 PM
By Greg Rosinski, Chemist II
Preparedness for a regulatory inspection can help to ease the stress in advance. Environmental Health and Safety Personnel involved in a Hazardous Waste Program should keep track of the follow items on regularly. The follow list is not the end all of lists, but it encompasses the major items an inspector will look for.
o The last three years of:
o Manifests
o Land Disposal Record’s (LDRs)
o Profiles for waste streams
o Main Accumulation Area inspections
o Make sure the site you are working at maintains up to date RCRA/OSHA/DOT records of each employee on site that works with Hazardous material.
o Generator needs to have the original EPA ID application, and the verification letter from the EPA
o Maintain complete compliance of Main Accumulation Areas (MAA) and Satellite Accumulation Areas (SAA).
o Keep any records of MAA or SAA compliance issues along with corrective actions taken.
o Spill Prevention, Control and Countermeasure Plan (SPCC Plan)
o Hazardous Communication Plan (HAZCOM) Plan
o Material and Safety Data Sheets (MSDS) of chemicals onsite
o In addition to the Waste profiles it is important to keep MSDS and any analytical along with a Non Hazardous Profile. This helps to support why the Non- Hazardous profile was chosen over a Hazardous Waste Profile.
o Compliance of Satellite Accumulation Areas with monthly Inspection Reports
o Check your states regulations regarding the management of recycled chemicals. This includes the labeling in an accumulation area.
In the event of an unplanned inspection from a regulatory agency should happen. Contacting specially trained compliance advisers within Triumvirate Environmental, Inc., gives a company the ability to have a pre-audit to review the compliance onsite before a regulatory agency comes onsite. Triumvirate Environmental, Inc. also can staff personnel that will come on site regularly to ensure continued compliance on site of Hazardous Waste Management.