What is a multimedia inspection? In multimedia inspections, the regulatory authority evaluates a facility’s overall compliance with environmental control or safety programs, rather than assess facility compliance on a media-specific basis. Multimedia inspections may also address environmental or safety performance issues, such as pollution prevention, that offer safety or environmental benefits beyond what is required by statute or regulation.
EPA
EPA‘s multimedia inspection is designed to look at all aspects of environmental impacts at once (e.g., air emissions, hazardous waste storage, and water discharges). This multimedia inspection approach is intended to make inspections and inspectors more efficient, because the facility is examined by just one inspector at one time rather than being deluged with several inspectors in piecemeal fashion.
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OSHA
OSHA may inspect workplaces for compliance with worker safety and health hazards. A Memorandum of Understanding authorizes EPA and OSHA to jointly inspect an organization or workplace where hazardous wastes are managed and where hazardous chemicals are manufactured, processed, or used.
During a joint EPA and OSHA inspection, an EPA inspector will focus on compliance with pollution control rules, while an OSHA inspector will check for compliance with OSHA‘s workplace health and safety standards.
DOT
In addition, both DOT and EPA enforce labeling, placarding, and marking rules associated with hazardous waste transportation.
States
State regulatory agencies responsible for administering pollution control rules and workplace safety and health standards are also authorized to conduct inspections.
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Four-Step Process
A well-designed program to minimize multimedia exposure should focus on the following four major tasks before the inspection:
Step 1: Identification of environmental noncompliance problems. Conducting a comprehensive, facility-wide audit or a series of process-specific or media-specific air, water, or waste audits is usually the best way to obtain this necessary information. These audits can be performed by a facility’s own environmental staff, consultants, or environmental attorneys.
Step 2: Evaluation of whether to use audit policies. Once noncompliance issues have been identified through the audit process, the facility should then take the second step by evaluating whether it will take advantage of one or more of the federal or state audit policies. An environmental audit is a self-evaluation process that allows an organization to determine whether it is meeting federal, state, or local regulations, as well as its own internal environmental objectives. An audit enables a company to recognize areas of noncompliance and to implement corrective measures before discovery by federal or state inspections.
Step 3: Development and implementation of a compliance strategy. The third pre-inspection step consists of developing a strategy to prioritize and address compliance issues and evaluate alternative compliance programs. The selected compliance programs should then be implemented in a timely manner and compliance issues resolved before any multimedia environmental inspection.
Step 4: Preparation of employees for multimedia environmental inspections. The fourth pre-inspection step involves the preparation of facility employees for interviews with inspectors. Employees should be aware of the potential consequences. To accomplish this objective, specific company staff should be selected to coordinate the inspection process and to accompany inspectors throughout the facility.
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