Good Morning, U.S. EPA is on Their Way…

This article is available as a podcast episode on ALL4’s Air Quality Insider   

“Good Morning, U.S. EPA is notifying your Facility that we will be on-site for an inspection on Wednesday and Thursday next week.  Attached is a list of items U.S. EPA would like to review while on-site.”

This is NOT the best notification to receive before heading into the weekend, especially when the accompanying document includes almost 20 specific items (with several corresponding bullet points) that require detailed responses.

If you are an environmental coordinator, what goes through your mind when you are notified of a surprise U.S. EPA on-site compliance inspection?  Fear?  Nervousness?  Confidence?  Regardless, the clock starts ticking and the countdown until your inspection has begun… are you prepared?

In this situation, the Facility (our client) sent the list of U.S. EPA requests to us to consider and we asked what type of support they wanted.  ALL4 has been working closely with this client for several years, so we felt good about where they stood regarding their air compliance status and so did they.  The client said that they would start going through the list and would ask us for support when needed.  And guess what… they did.  We even provided “non-visible” on-site support so that we could quickly respond if anything came up.

Unfortunately, surprise U.S. EPA compliance inspections are a fact of life for large industrial facilities.  The good news is that ALL4 has provided support to our clients before, during, and after various Federal and State compliance inspections.

Here are a few tips when preparing for an inspection, surprise or otherwise:

• Compile documentation in advance

If the inspection agency provides a list of items to review, you have a great roadmap.  To confirm you are prepared and allow for an efficient inspection, (1) Set up electronic files in labeled folders that correspond to the list of information requested by U.S. EPA and (2) Print out hard copies of information that would be best reviewed on paper.

• Expect the unexpected

Be prepared to provide a detailed tour of the Facility to the inspectors.  This includes having sufficient personal protective equipment (PPE) on hand and designating a single conference room for documentation review.  The inspectors can request additional information on the fly or even ask for all of the files to be provided on a USB drive that they can take with them.

• Don’t BS!

If you don’t have a file handy or you are unsure about something, do not BS the inspectors.  Simply let them know that you are unsure and you can follow up with the appropriate file or answer after the inspection.

• Ask “what comes next?”

Before the inspection comes to an end, ask the inspectors “what comes next?”  For example, should the Facility expect a written inspection report within two weeks?  A conference call the next day?  Follow up items to be requested?

In the event that you “get the call” from a regulator to announce an inspection, ALL4 can assist your Facility before (document prep), during (assisting your Facility Environmental contact), and after your inspection (follow-up support).  We also perform compliance audits and assessments, which can be used to better prepare facilities in advance of these surprise inspections.

Do you have an upcoming inspection and could use support?  Have you looked at your records recently to ensure that you have everything required by your operating permit organized and easily accessible?  Have you considered pre-emptively reviewing your documentation, organizing, and structuring your files in case an inspection comes up?  Have you had a good or bad experience with an inspector?  Share your experience below or feel free to reach out to any of our consultants to talk about it!  You can reach me at 610.933.5246 x129 or aessner@all4inc.com if you want to chat about my experience or need a hand.