When an environmental compliance inspector shows up at your door, you want to be prepared. If you aren’t, you may be frantically scrambling to find required documents and information. Proper preparation not only helps the inspection to go smoothly, but also provides a good first impression and is crucial to avoid enforcement actions.
Understanding what to expect during an inspection, staying organized and performing your own internal audits, will have you ready for an inspection at any time. Taking these steps and understanding the inspection process will prevent panic when an inspector arrives, giving you confidence that your inspection will go well.
Why You May Get an Environmental Compliance Inspection
An agency inspection may be planned or unannounced, and may be conducted for numerous reasons, including:
- Determining compliance with a permitted activity or in response to a permit application
- Determining compliance with a specific permit condition
- Evidence of a violation
- Follow-up check on prior violations
- Response to a citizen or employee complaint (such as an odor or nuisance)
- Referral from another agency
Typically, only one area of environmental compliance (such as air, water, or waste) is the subject of the agency visit.
Tips for Handling an Agency Inspection
Knowing what is included in an environmental compliance inspection allows you to better prepare. By understanding the steps, you’ll know what questions to ask, what documents to have ready, and what to expect from your inspector.
Designate a Primary Contact
Your facility should have pre-determined procedures for handling government agency inspections. These procedures should identify a primary contact. All employees should know to politely defer questions to the primary contact, which could be your Environmental, Health, and Safety (EHS) officer or other company representative.
The designated contact, should request the inspector’s credentials. You can verify the inspector’s identity by checking with the nearest regional office if you have doubts. Keep records of the names of all persons conducting or attending the inspection.
The designated contact should also ask the inspector about the purpose of the inspection and the applicable standard. If a complaint has sparked the investigation, ask to see a copy of the complaint.
Before the inspection begins, there will be a meeting between the inspector and company officials. The inspector will use this time to ask questions about your facility and operations and explain the documents they will need to review.
This is also the ideal time for you to ask the inspector any questions you might have. These might be questions involving the timeline of the inspection, proprietary or confidentiality concerns, or any other possible issues. To help the facility inspection go more smoothly, make sure your inspector also understands your safety procedures and operating hours.
During the Inspection
Accompany the inspector throughout the visit. Use the most direct route to access the areas the inspector wants to see, avoiding areas that are not part of the inspection. Be polite and courteous, but restrict the inspection to the stated purposed and legally required reports and files.
Documentation review will be a major part of the inspection process. These documents can include:
- Waste disposal records
- Safety Data Sheets (SDSs)
- Emergency response plans and/or spill plans
- Training records
- Material purchasing records
- Operation records
Keeping these records well organized and easily accessible at your facility will allow your environmental inspection to move efficiently and will demonstrate your capability and competence.
The inspector will be examining facility operations and may take photographs at your facility. Make sure you also take a photograph so you have a duplicate for your records.
The inspector may also conduct interviews with personnel to see how operations and procedures are understood and handled. Be sure your personnel are instructed to be relaxed and cooperative but not to volunteer unnecessary information. They should take notes covering everything that is said during the inspection for you to keep on file.
If a violation is cited, correct it on the spot if it is possible to do so.
Once the inspection is complete, the inspector will discuss any issues or violations found during the inspection. If there are violations found, the inspector will explain action items you can take to correct the problem. They will also set a timeframe in which the violation needs to be corrected and create a plan to follow up with your facility. Request a copy of the inspection form before the inspector leaves. Also request a copy of the final report when it is prepared.
Prepare your own inspection report as well. Acknowledge the findings of the inspector, including a list of all cited violations and corrective actions required. Gather notes and photographs taken during the inspection and keep these filed together.
If you receive a notice of violation or any other type of correspondence from the agency identifying violations and corrective actions, do not ignore it! If issues are addressed in a timely and responsible manner, your violations may not necessarily result in monetary penalties. Agency guidance suggests that you stay in contact with you inspector until you have reached resolution.
Be Prepared for an Environmental Compliance Inspection
Being prepared for your environmental compliance inspection is a key element in how well your inspection will go. There are two major ways you can always remain prepared for any surprise inspections: staying organized and performing regular internal audits.
Because documentation is such a crucial part of any environmental compliance inspection, keeping your documents well organized and easily accessible is one of the most important things you can do to be prepared. Make sure you know what records your facility is required to keep and how long those records must be kept. Then have a system in place that ensures these records are properly maintained and well organized.
Performing regular internal audits at your facility will also go a long way in making sure you are always prepared for any surprise visits from government agencies. While an internal audit may sound time consuming in the short term, it will ultimately save you time and help avoid potential violations and fines.
Get Support from Tetra Tech
If you need help preparing for an environmental compliance inspection or performing your own internal audit, contact Tetra Tech’s EHS professionals at [email protected]. Our team can help you understand your documentation requirements, create systems that will enable you to stay organized, and assist you with performing internal audits
Environmental compliance inspections may sound overwhelming, but they don’t have to be if you are properly prepared. Contact us for support today.