EPA INSPECTIONS: Preparing for, and responding to a surprise inspection
In my recent experience with EPA inspections focused toward laboratory and hazardous waste management, it has become apparent that preparation for a surprise inspection is every bit as important as properly responding to an inspection. While this is by no means an all-inclusive guide to successfully handling an EPA inspection, the following should serve as an outline of key points to consider prior to and during an inspection:
- Is your emergency contact information accurate and up to date?
- This may be one of the first things an inspector delves into upon arrival at your facility. Additionally, it is important to test your primary and secondary methods of acquiring an MSDS in the event of an emergency. For example: if you have identified that MSDS's will be obtained via the internet in the event of an emergency, you should also be sure that you are familiar with an alternative method such as calling an emergency MSDS hotline and that an MSDS can be faxed to your facility on short order.
- Is your Main Accumulation Area (MAA) well maintained, in compliance, and is your weekly MAA inspection log complete and up to date?
- Proper MAA maintenance is intrinsically linked to running a top notch Haz-Waste management program at your facility. 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. Don't forget to make sure all emergency contact info is conspicuously posted and a phone is located inside of or very close by the MAA
- Weekly MAA inspection logs are to be kept on file for 3 years. It is crucial that there are no gaps in the records. Be sure to take into account long weekends and holiday schedules. If you can present a simple SOP geared towards accommodating for such circumstances, all the better!
- How well are your laboratories maintained? Are training records kept on file and readily available?
- Once inside the lab, an inspector will most likely ‘interview' lab staff. Questions will focus on waste management, safety procedures, and chemical compatibility issues in your chemical storage cabinets.
- RCRA is all about records. Be sure that all laboratory training records and lab SOPs are available.
- Out of date, unusable, or excessive amounts of chemicals should not be stored in the lab. Chemical storage/labeling issues raise a red flag, and are viewed as an indicator of poor lab practices