This means you have to be the expert on what’s going on in your facility and what federal environmental laws apply to it. Information gathered as part of the voluntary audit pre-inspection process will help you do just that.
To help you use your time wisely during this arduous task, here’s a checklist of the types of information you need to gather for a thorough pre-inspection. This information covers your readiness for an audit, general information on your facility, and what you need for worker training. See tomorrow’s Advisor for another, more specific checklist that covers air, water, waste, SPCC, and other important environmental laws.
Ready for an Audit?
1. Have you gathered and examined the following paperwork to be used in the self-audit:
- A facility description and map?
- Your company’s regulatory history?
- Your company’s existing compliance programs?
- Records on compliance procedures (e.g., monitoring, work practices, recordkeeping, and reporting)?
- Records on employee training?
- Records on medical examinations?
- Current environmental permits?
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2. Have you created a written list of potential problem areas to be confirmed during the next phase of the self-audit?
3. Have you allocated sufficient time to do the following:
- Make a visual inspection of the facility?
- Conduct interviews with selected facility personnel?
4. Are you familiar enough with the paperwork listed in Question #1 to be able to validate them during this phase of the self-audit?
5. Are you on the alert to identify additional problem areas that were previously unknown?
6. Are you prepared to describe all areas of noncompliance uncovered during the self-audit?
7. Do you know what tools to apply to a careful assessment of potential liabilities?
8. Are you prepared to offer an economic analysis of the costs of compliance as well as continued noncompliance?
9. Do you have ready specific recommendations for corrective measures to be taken in noncompliance situations?
10. Do you have access to the resources that can provide you with reliable estimates of the costs of any recommendations you may make?
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General Information
1. Have you identified the following information:
- Name and address of the facility?
- Primary operation at the facility, including all applicable SIC codes?
- Each process or potential source of pollution at the facility?
- Chemicals used at the facility?
- Raw materials used at the facility?
- Pollution control devices and/or waste minimization operations at the facility?
- Installation date of each process or potential source of pollution at the facility?
- Primary operation of the previous owner/operator/occupant of the facility?
- History of spills and other accidents at the facility?
2. Do you know whether the equipment or machinery utilized fluids containing polychlorinated biphenyls (PBCs) (e.g., hydraulic fluid, di-electric oil, or transformers)?
3. Have you studied your company’s environmental management history and identified all the waste streams (e.g., air, water, waste, hazardous waste)?
4. Have you reviewed the following environmental management records and files and determined if any are current or still in effect:
- Permits and support documentation?
- Flow sheets?
- Air-emissions inventories?
- Sampling records?
- Analytical techniques?
- Maintenance records?
- Operating logs?
- Periodic reports filed with federal and state regulatory agencies and other documents in their possession?
- Reports of any actions that exceeded permit requisites?
- Emergency Action Plan?
- Oil Spill and Hazardous Substances Contingency Plan?
- Spill Prevention, Control, and Countermeasure Plan (SPCC)?
- Stormwater Pollution Prevention Plan (SWPPP)?
- Notification procedures?
- Electrical transformer labeling, storage, and disposal records?
- Other waste-disposal files (e.g., hazardous, nonhazardous, or manifests)?
5. For all permits identified, have you also reviewed and checked the following information:
- Type of chemicals and activities that were permitted?
- Compliance history?
- Inspection and enforcement history?
6. Have you obtained copies of the following:
- Permits?
- Licenses?
7. Have you located any topographic maps that depict prior or current uses or conditions of land?
8. Do you know who is responsible for worker-right- to-know requirements?
Worker Training
1. Do you know what type of worker training is required under the following laws:
- OSHA’s Hazard Communication Standard (HCS)?
- Resource Conservation and Recovery Act (RCRA)?
- Clean Water Act (CWA)?
- Clean Air Act (CAA)?
- Other applicable provisions?
2. Have you documented what type of training has been conducted under each of the following laws:
- OSHA’s HCS?
- RCRA?
- CWA?
- CAA?
- Other applicable provisions?
3. Do you know who maintains the training records required under each of the following laws:
- OSHA’s HCS?
- RCRA?
- CWA?
- CAA?
- Other applicable provisions?
See tomorrow’s Advisor for more topic-specific pre-inspection checklist.