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How to Survive, or even Thrive, an Environmental Inspection

How to Survive, or even Thrive, an Environmental Inspection. Norman Umberger, P.E. ASSE Delmarva Feb. 2010. Environmental?. Why should Safety Professionals be interested in Environmental inspections? Who is an Environmental inspector? When will I be inspected?

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How to Survive, or even Thrive, an Environmental Inspection

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  1. How to Survive,or even Thrive,an Environmental Inspection Norman Umberger, P.E. ASSE Delmarva Feb. 2010

  2. Environmental? • Why should Safety Professionals be interested in Environmental inspections? • Who is an Environmental inspector? • When will I be inspected? • What is an Environmental inspection? • How can Safety & Environmental interact? • Your Questions & some Answers…

  3. Why should I? • Often thought of as the same profession… • Safety plays a part… • Insight into our Safety… • Legal overlap…

  4. Who is this guy? • Federal/State/Local • Usually green • Usually generalist • INECE: “The Inspector plays crucial role in motivating companies to comply with Environmental regulations…. The more effective the inspector can be, the higher the rates of compliance.”

  5. Environmental Programs • Clean Air Act (CAA(A)) • Clean Water Act (CWA) • Emergency Protection & Community Right-to-know Act (EPCRA) • Federal Insecticide, Fungicide,& Rodenticide Act (FIFRA) • Resource Conservation & Recovery Act (RCRA) • Safe Drinking Water Act (SDWA) • Toxic Substances Control Act (TSCA) • Marine Protection, Research & Sanctuaries Act (MPRSA)

  6. When will they? • A specific environmental problem • A specific facility • A specific industry • A specific area (geographic or system) OR • Your permit compliance • Complaints (internal/community)

  7. Scope • Usually a single media (e.g., water) • Maybe multi-media (e.g., air, waste) • Can be limited to a problem • Follow-up due to compliance status

  8. What is this? Inspections: Gathering information to determine facility’s compliance

  9. Procedure • Pre-inspection activities • Opening Conference • Interviews (management & employees) • Record Review • Walk-Through observing operations • Sample Collection • Closing Conference

  10. Pre-Inspection Regulatory Agency: • Reviews their records • Plans inspection • Assigns personnel

  11. Pre-Inspection You: • Review your records • Audit/Mock/Plan inspection • Assign personnel

  12. Opening Conference Agency: • Introduction of personnel • Review purpose & scope

  13. Opening Conference You: • SAFETY briefing • Adapt preparations to Scope • Alert Chain-of-Command

  14. Interviews Agency: • Learn about facility operations • Determine if today is different • Determine if folks know • Likely interview floor personnel

  15. Interviews You: • Explain facility operations • Direct to knowledge • Direct away from problems • Try to learn and then correct answers from floor personnel

  16. Record Review Agency: • Review documentation of required actions under permits/programs • Often follows a program checklist • Check into Training records

  17. Record Review You: • Often incomplete, plan for follow-up • Often too revealing, segregate files • Learn retention times (5 yrs)

  18. Walk-Through Agency: • Tour of the facility, guided by your personnel, concentrating on the covered processes • The inspection team will ask questions and compare what they see to permits and regulations

  19. Walk-Through You: • Concentrating on scope… • Listen • Respond (truthfully) • Do NOT volunteer • Speculate little • Correct what you can • SAFETY First

  20. Sample Collection Agency: • Collect physical samples • Photograph equipment/processes

  21. Sample Collection You: • Request splits • Take duplicates • Make notes • Request CBI/trade secret protection

  22. Closing Conference Agency: • Outline preliminary findings • Provide guidance for compliance • Schedule next steps

  23. Closing Conference You: • Make comprehensive notes • Ask questions • Provide follow-up information • Schedule next steps

  24. Interactions • MOA to share info between OSHA/Env. • Overlap esp. in chemicals, labeling, etc. • Housekeeping • No one document

  25. Concluding Nuggets • Prepare • Practice • Participate • Professional • Cooperative • Courteous

  26. Resources • http://www.epa.gov/compliance/monitoring/inspections/index.html • http://www.epa-echo.gov/echo/

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