Coping with Environmental Agency Inspections--When the inspector comes knocking!; Bauer, Jerry; Burns & McDonnell; 2014 Mid-America Environmental Compliance Conference
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Coping with Environmental Agency Inspections--When the inspector comes knocking!; Bauer, Jerry; Burns & McDonnell; 2014 Mid-America Environmental Compliance Conference

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Coping with Environmental Agency Inspections--When the inspector comes knocking!; Bauer, Jerry; Burns & McDonnell; 2014 Mid-America Environmental Compliance Conference Coping with Environmental Agency Inspections--When the inspector comes knocking!; Bauer, Jerry; Burns & McDonnell; 2014 Mid-America Environmental Compliance Conference Presentation Transcript

  • Coping with Environmental Agency Inspections When the inspector comes knocking! Jerry P. Bauer, P.E. Burns & McDonnell Engineering Company November 2013
  • Environmental Agency Inspections What to do……. •Before the inspection •During the inspection •After the inspection 56804_United Pumping Services
  • Before the Inspection (What to do) Develop an “Environmental Regulatory Inspections” Policy •Define Company Policies and Procedures Associated with Managing Environmental Agency Inspections (Guide the person in the hot seat when the inspector shows up). View slide
  • Before the Inspection (What to do) Advantages of Having Written Policy •Quick Reference Guide (especially if regular contact is absent) •Support Environmental Coordinator in taking hard line •Uniform Company Position/No Second Guessing 56804_United Pumping Services View slide
  • Before the Inspection Company Inspection Policy 1.Verify Inspector Credentials 2.Determine Purpose 3.Cameras and Audio Equipment ??? 4.Company escort required 5.Records provided to inspector 6.Exit Meeting 7.Signatures on Inspection Form ?? 8.Notifications to Plant Manager/Attorney 56804_United Pumping Services
  • Before the Inspection (What to do) Advantages of Well Organized Environmental Records 1. Able to Provide Requested Records 2. Avoid Providing too Much Information 3. Get Inspector Out the Door 4. Appearances Count 56804_United Pumping Services
  • Before the Inspection Good Housekeeping and Maintaining an Orderly Facility •Appearances Count-Chemical spills, open containers, unlabeled containers look bad (and may be violations) •Eliminate the “low hanging fruit” 56804_United Pumping Services
  • Before the Inspection Examples of Low Hanging Fruit •Fluorescent Bulbs- Containers not dated/closed 56804_United Pumping Services
  • Before the Inspection Examples of Low Hanging Fruit •Parts Washer Solvent- Lid not closed 56804_United Pumping Services
  • Facts of Life Despite Your Hard Work and Preparation… 1.You May be Out-Gunned (Ozone Depleting Compound/40 CFR Part 82 or SPCC Inspector) 2. Deck May be Stacked Against You (Prevention of Significant Deterioration (PSD) Review) 3. Success will be highly dependent on the inspector! 56804_United Pumping Services
  • The Inspector • You know it will be a good day when your inspector looks like….. 56804_United Pumping Services
  • The Inspector • You know it will be a bad day when your inspector looks like….. 56804_United Pumping Services
  • The Day of the Inspection Quickly Review Company Policy and … •Verify Inspector Credentials •Inquire about purpose of inspection/request inspector documents •Notify (Plant manager, attorney, etc) •Set up in dedicated conference room •Confirm Ground Rules (No photos, escort at all times, etc.)
  • The Day of the Inspection Inspection Components • Visual/Odor Observation/Walk-Through • Personnel Interviews • Records Review
  • Day of the Inspection Walk-Through/Plant Tour •Show Auditor requested area (no more) •Safety training and personal protective equipment •No Safety Shortcuts •Straight line to requested areas
  • Day of the Inspection Inspector Interviews Examples of employees to interview: • Boiler operator • Visible emissions observer • Refrigerant Technician • Monthly SPCC Inspector • Maintenance Personnel • Leak Detection Inspector • Operator (Painter, Assembler, etc.)
  • Day of the Inspection Inspector Interviews • If Inspector asks to interview specific person… • If Inspector request is more general: • Avoid the “loose cannon” • Avoid employee with axe to grind • “Cherry Picking” is ok
  • Day of the Inspection Records Review •Put Auditor in conference room (remote from records) •Provide records requested; no more, no less •Copy and provide requested records
  • Day of the Inspection Exit Meeting • Always a good practice! • Obtain and document as much as practical •Don’t argue “big ticket items” but correct factual mistakes • Ask for written report • Inform inspector if corrected on-site (day of inspection)
  • After the Inspection If Issues/Findings Identified…. •Consider Pro-Active Response to Audit (Before letter/Notice Of Violation Received) •Respond to Formal Requests for Information, Letters, or NOVs •Take Corrective Actions to Prevent Recurrence
  • Summary and Recommendations 1. Have a policy in place before the inspection. 2. On the day of inspection: a. Provide records requested – no extras b. Answer questions asked – nothing else c. Show inspector areas requested- no more d. Being an a**h*** never helps- and can make the situation much worse 3. Respond Promptly to Inspection reports