Enforcement and Inspection

A-Z Pre-Inspection Checklist for EHS Regs

Hazardous Waste

  1.  Do you know if solid wastes are generated at the facility?
  1. If solid wastes are generated at the facility, have you listed the following information:
  2. –Type of waste?
    –Quantity?
    –Result of which process?
    –Storage, if any?
    –Disposition?

  1.  Are characteristic hazwastes generated at the facility?
  1.  If characteristic hazwastes are generated at the facility, have you listed the following information:
  2. –Type of waste?
    –Quantity?
    –Result of which process?
    –Storage, if any?
    –Disposition?

Water Quality

  1. Does your company have a National Pollution Discharge Elimination System (NPDES) permit?
  2.  Is your site or facility covered under a NPDES Stormwater permit?
  3.  Do you know whether your company is disposing of any chemicals in wastewater that are not covered by the NPDES permit?
  4.  Is pollution control equipment being properly maintained?
  5.  Is your company monitoring wastewater properly?
  6.  Do you know whether any variations in effluent are not accounted for by production changes?

 

Spill Prevention and Control

  1. Is your facility required to have a Spill Prevention, Control, and Countermeasure Plan (SPCC Plan?)
  2. Have you provided required secondary containment for containers and vessels?
  3. Is your spill prevention equipment being properly maintained?

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Air Quality

  1.  Does your facility have the appropriate construction and/or operating air emissions permits?
  2. Is emissions control equipment being maintained properly?
  3. Do you know if any permit violations have occurred?
  4. Have you checked to find out if any other requirements apply?
  5. Is the facility located in a nonattainment area?
  6.  Is the facility a “major source”?
  7. Is the faciltiy a “synthetic minor source”?
  8.  Is the facility a “natural minor source”?
  9.  Are the facility’s air emissions being accurately quantified and documented in an air emissions
  10. inventory?
  11.  Is the air emissions inventory being compiled according to the frequency outlined in any applicable
  12. permit?
  13.  Is each piece of equipment in compliance with the terms and conditions of its permit?

 

Asbestos

  1. Do you know if friable asbestos is present?
  2. If friable asbestos is present, do you know where it is located?
  3. Do you know if air sampling is being conducted?
  4.  Have your engineering controls been put in place?
  5. If your engineering controls have been put in place, are you aware of any warning signs of
  6. contamination?
  7.  Is medical surveillance being done?
  8. Do you know who keeps medical records?

 

Toxic Substance Control Act (TSCA)

  1.  Do you know whether your company manufactures or imports any chemicals not listed on the
  2. chemical inventory?
  3. Have premanufacture notices been submitted?
  4. Do you know whether your company has or uses any chemicals banned under the TSCA?
  5.  Do you know who is responsible for keeping the required records?

 

Community Right to Know

    • Do you know what you are required to do under the following provisions:
    • Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
    • data sheets (MSDS)?
    • SARA Title III, Section 312: Tier I/Tier II?
    • SARA Title II, Section 313: toxic chemical release forms?
    • Do you know what required reporting has been completed under the following provisions:
    • Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
    • data sheets (MSDS)?
    • SARA Title III, Section 312: Tier I/Tier II?
    • SARA Title II, Section 313: toxic chemical release forms?
    • Do you know who is responsible for the required reporting under the following provisions:
    • Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
    • data sheets (MSDS)?
    • SARA Title III, Section 312: Tier I/Tier II?
    • SARA Title II, Section 313: toxic chemical release forms?

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    Worker Right to Know

    1. Has your workplace been evaluated for hazardous chemicals?
    2. Have you checked to see that hazardous chemical containers are labeled properly?
    3.  Have MSDSs been obtained or developed?
    4. Do you know where the MSDSs are located?

     

    Recordkeeping

    1.  Are you familiar with the required recordkeeping under each of the following:
      • RCRA?
      •  CWA?
      • CAA?
      • Asbestos?
      • TSCA?
      • Community Right-to-Know?
      • Worker Right-to-Know?
      • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
      • Applicable state laws?
      • Each valid permit for the facility?
    2. Do you know which person or department is responsible for the required recordkeeping under each of the following:
      • RCRA?
      • CWA?
      • CAA?
      • Asbestos?
      • TSCA?
      • Community Right-to-Know?
      • Worker Right-to-Know?
      •  Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
      • Applicable state laws?
      • Each valid permit for the facility?