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Today’s environmental regulations are so complex and far reaching, even the most knowledgeable, dedicated, and conscientious environmental manager is likely to quake at the thought of an agency inspection. But there are plenty of things that can and should be done in advance to help mitigate some of the stress a pending inspection can cause.
First and foremost, know and understand all the laws and regulations that apply to facility operations. Even if you are sure facility operations are in compliance, make it a regular task to check for rule changes, updates, and clarifications that could impact your compliance status and incorporate new changes into your compliance activities and documents as necessary.
Similarly, be sure to carefully review and become familiar with all previous inspection reports, corrective actions taken, and any available correspondence involved with inspections, violations, and related actions. Next, make sure each problem area has been addressed appropriately, that any required documentation has been submitted to the agency with jurisdiction, and outstanding issues are resolved.
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Another regularly occurring activity should be an environmental audit of your facility. Depending on which regulations apply and what specific permits require timing may vary, but audits should take place often enough that questions would not go unanswered if an inspector showed up today. Keep records, and follow all reporting requirements as prescribed in each regulation.
It is also essential to keep all documented compliance programs, processes, checklists, and records up to date, organized, and available for review. Since it is very likely documentation will be included in an inspection, be prepared to provide an inspector with a room or other area free from disturbances for their use during documentation review conferences and any closing briefings provided to wrap up the inspection.
One easily forgotten aspect of inspection preparation is that of other employees, from management to maintenance. Starting at the top, instruct management about all aspects of the facility’s operations and the applicable regulations covering environmental and safety and health compliance programs, making sure that they are well versed in the physical layout of the facility and the inspection process. It is also important to determine ahead of time whether management will want legal counsel to attend inspections. This should be discussed with both management and legal counsel to determine what is preferable, well in advance of any inspection.
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Take the time to observe nonmanagement employees as well to make sure they are following rules, complying with regulatory requirements and working safely at all times. Compare employee training requirements for each regulation and associated employee training program records to ensure training is up to date and employees are knowledgeable about the regulations that apply to them, their work area, and job functions.
Also regarding employees is the appointment of qualified staff and a backup to serve as the representative in the event of an inspection. This person should be very well versed in all compliance areas, knowledgeable about documentation and recordkeeping, and able to discuss past and present compliance activities with authority and confidence.
These are some of the most important best practices for environmental managers to follow in preparation for an environmental inspection. Tomorrow we will look closer at things to know and do on inspection day.