EPA INSPECTIONS – QUESTIONS TO BE PREPARED FOR AND OTHER TIPS
It’s never too soon to start planning for an EPA Inspection. Here are some tips to help you be better prepared in the event that an inspector shows up.
In general, an inspector will assess the effectiveness of your facility's environmental and safety programs by asking environmental, operations, and maintenance staff to answer a series of general questions. You can be prepared by being able to answer the following questions
1. How are regulatory requirements determined and communicated?
2. How is compliance monitored?
3. What is the effectiveness of the internal communication systems, particularly under spill or release scenarios?
4. What is the existence and completeness of detailed process flow charts and mass balances?
5. How is noncompliance communicated to management?
6. Is environmental and safety compliance a factor in job performance evaluations?
7. What is the existence and scope of an environmental and safety training program?
8. What are the existence, scope, and maturity of the facility's environmental management system?
Tips: During the Inspection
Here’s how you can make the inspection of your facility go as smoothly as possible:
Cooperate. The most important advice to follow during an inspection is to cooperate with the inspector. The inspector may equate non-cooperation with regulatory noncompliance.
Accompany the inspector. The facility owner, operator, or workplace supervisor should accompany the inspector during the inspection to take notes on the inspector's comments. When accompanying the inspector, pay particular attention to questions that the inspector asks you or employees about workplace health and safety or waste management practices.
Correct errors. It is also important, if possible or if requested by the inspector, to correct regulatory problems, such as a malfunctioning chemical-treatment-process machine or a minor spill, during the inspection.
Duplicate samples and records. Should the inspector take samples of your wastestream, take a sample of the same wastestream at the same time so that you have nearly identical samples. Ask the inspector what test or analysis the sample will undergo and have the same test or analysis conducted independently on your sample for your own records.
Should the inspector request copies of corporate records, either make the copies then, or if the request requires a substantial amount of copying, agree to the inspector's copying schedule. A second set of the requested copies should be made for your inspection records. The inspector may also take pictures of relevant plant equipment or manufacturing processes. You should take the same pictures.
Compliance Assistance by Inspectors
EPA recognizes that federal inspectors do and probably should provide assistance to facilities. EPA believes that it is appropriate for federal inspectors to provide information such as copies of requirements, guidance documents, manuals, technical articles, and pollution prevention reports. More technically complex and site-specific assistance, such as information about compliance status, including pollution prevention and control technologies, may be offered.
However, certain assistance, such as information on specific consultant services and detailed facility-specific engineering design and materials management information, is generally not appropriate.