It’s no secret that Environmental Protection Agency (EPA) has increased both on-site inspections and off-site monitoring actions each year since 2021, according to its own enforcement data.
The ultimate goal of any regulatory agency inspector is to monitor and enforce compliance with existing environmental laws and regulations. EPA inspections are incredibly complex and critical endeavors that demand vigilance and attention to detail. Fortunately, there are actions you can take before an inspection to help prevent being on the receiving end of enforcement actions.
Know the Requirements
Stay up to date with changing EPA regulations and be aware of ongoing regulatory activity, including newly proposed and finalized regulations at the federal, state, and local levels. Familiarity with the equipment and processes allows you evaluate what federal, state, and local regulatory requirements are applicable.
Review regulations relating to different operations in your facility, as well as the provisions of any permits issued to your facility by a regulatory agency, to see that you comply with the most recent rules and permit requirements. Confirm that you have a method for documenting compliance with all regulatory requirements and permit conditions such as inspection, monitoring, and reporting requirements
Compliance with applicable regulations and permit conditions can be assessed through regular inspections and compliance audits. Be prepared to acknowledge areas of noncompliance that may be uncovered during an inspection or audit and document the corrective measures you are taking to come into compliance. It is also helpful to know your facility’s compliance history. The agency inspector will likely do research on where you may have had compliance issues in the past and may be more aggressive to assess those areas.
Know Your Operation
It is crucial that you have a good understanding of the operations at your facility, including all equipment, machinery, processes and pollution control devices, as well as any potential sources of pollution at the facility. For each process or piece of equipment you should know the installation date, chemicals and raw materials used and operating schedules; you also should be able to identify all the waste streams (e.g., air, water, waste, hazardous waste) and efforts to minimize those waste streams.
It is beneficial to make regular visual inspections of the facility, conduct interviews with selected facility personnel, and observe employees at work to see that they are working in an environmentally safe and compliant manner.
Be Organized
Emphasize good housekeeping throughout the facility. See that all areas of the facility are in good working order, and that everything is properly labeled and in its designated location. Keeping all areas of the facility clean and organized helps minimize the potential for accidents and will create a good impression. Just as important is having your paperwork in order.
Have all your records, training documentation, permits, and other documents organized and readily accessible. One of the first things an inspector will do during an inspection is request to review your records, including permits, required monitoring and recordkeeping information, and most likely a facility map. So be consistently diligent in seeing that you have well-organized and accessible records.
Consider Third-Party Auditing
A third-party compliance audit is an independent, unbiased evaluation of a company’s compliance with applicable environmental regulations and industry standards. Oftentimes, managers in charge of facilities are challenged to keep up with other responsibilities while also keeping up with compliance documents and changing environmental compliance regulations. Third-party audits allow managers to feel confident knowing their facilities are being assessed by an unbiased third party who will identify compliance deficiencies and help with corrective actions.
Environmental auditing companies with extensive experience providing integrated multimedia compliance audits for industrial facilities, commercial operations, energy companies, aviation facilities and federal installations can help guide project owners through the EPA inspection process. Qualified auditors can conduct environmental compliance and management system audits that evaluate current compliance status with applicable federal, state and local requirements. A high-quality auditing team should be well equipped to prepare detailed reports to suit client needs, including addressing regulatory citations, summarizing regulatory requirements and reporting observations and findings regarding the status of compliance and recommended corrective actions.
Approach Inspections with Confidence
Inspections can be challenging but are necessary to maintain regulatory standards and protect people and the environment. If inspections aren’t properly handled, facility owners could face significant penalties, unwanted public scrutiny and operational disruptions. Facility operators can reduce the possibility of failed inspections by staying informed about regulatory changes, maintaining thorough documentation, understanding the ins and outs of their operations, and considering third-party audits to achieve compliance.
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