Are you prepared for a knock on your door by a regulatory agency?
Posted on Tue, Mar 10, 2009 @ 08:32 AM
by Sandy Perry, Consulting Services Manager/Principal Consultant
First of all, you have to let them in...the regulations are clear about that. So it's best to prepare your organization for that eventuality. It is a known fact that a state agency and/or EPA inspection follows soon after a facility files notification of becoming a large quantity generator of hazardous waste. Additionally, these agencies have a list of facilities to inspect on a cyclical basis. Do they target certain industries - hospitals, biotech companies, chemical manufacturers? There have been EPA initiatives in the past and there's nothing to say that state agencies don't also follow suit. So my point is...get ready! Here are a few tips on "how":
1. Develop and have an up-to-date contact list at the front desk and make sure those individuals receive proper instruction on when and who to call when an agency inspector walks in the door.
2. Have all of your paperwork in order and in one centralized location if at all possible including: hazardous waste manifests/shipping papers (3 years is all you need, store the rest elsewhere), wastewater monitoring records and lab data, oil storage inventory records, employee training records, and facility plans - Hazardous Waste Contingency, Emergency Response, Oil SPCC, Storm Water Pollution Prevention, as well as your permits for flammables storage, air emissions from boilers and emergency generators, etc.
3. Conduct a mock inspection as an employee training exercise. Have a list of typical questions asked by the agency ready, and be prepared to counsel those on the floor with respect to their behavior and nature of their answers. Being respectful is number 1 of course, but they should also not be shy about asking for clarification if they don't understand the question, and should not offer up opinions or other information beyond what is being asked.
4. And finally, make sure your "house is in order" and that you are organized. Your inspection is likely to go so much better if their impression is that your company's programs are well implemented and your staff is knowledgeable.
An agency inspection can be nerve-racking, and unfortunately we all know that despite our best intentions, they will probably find "something". Don't sweat it, call your trusted environmental advisor if you need help, and above all - be prepared; it's your best line of defense!