Everyday actions to simplify EPA inspections

No one looks forward to the day when the regulatory authority arrives at your facility for an inspection, but are you ready for when that day arrives?

EPA inspections are on the rise. During the pandemic, onsite inspections declined, and EPA emphasized off-site compliance monitoring activities, or actions the agency could take to evaluate compliance without being onsite. However, during fiscal year 2022, EPA’s onsite inspections increased 78% over the previous year, while continuing to maintain the previous year’s level of off-site compliance monitoring activities. But this dramatic increase only tells part of the story, as many inspections are conducted at the state or local level.

The goal of the regulatory agency inspector is to ensure that your facility or business operates within compliance, but sometimes this means costly penalties. However, there are actions you can take before the inspection to help prevent being on the receiving end of enforcement actions.

You may not know when an inspection is coming, but there are things you can do every day to be prepared for the day when the compliance officer knocks on your door.

Know your operations

It is critical that you have a good understanding of the operations at your facility, including all the equipment, machinery, processes, and pollution control devices, as well as any potential sources of pollution at the facility. For each process or piece of equipment, you should know the installation dates, chemicals and raw materials used, operating schedules, and be able to identify all the waste streams (e.g., air, water, waste, hazardous waste) and efforts to minimize those waste streams.

It is beneficial to allocate sufficient time to make regular visual inspections of the facility, conduct interviews with selected facility personnel, and observe employees at work to make sure they are working in an environmentally safe and compliant manner.

Know the requirements

Familiarity with the equipment and process operations allows you to evaluate what federal, state, and local regulatory requirements are applicable to such operations. Stay up to date with changing regulations by implementing a system to ensure you’re aware of ongoing regulatory activity, including newly proposed and finalized regulations at the federal, state, and local levels.

Review the regulations relating to all the different operations in your facility, as well as the provisions of any permits issued to your facility by a regulatory agency, to make sure you comply with the most recent rules and permit requirements. Ensure that you have a method for documenting compliance with all regulatory requirements and permit conditions – know your monitoring, recordkeeping, and reporting requirements.

Compliance with applicable regulations and permit conditions can be assessed through regular inspections and compliance audits. Be prepared to acknowledge areas of noncompliance that may be uncovered during an inspection or audit and document the corrective measures you are taking to come into compliance.

It is also helpful to know your facility’s compliance history. The agency inspector will do research on where you may have had compliance issues in the past and may be eager to assess those areas, so don’t be caught off guard.

Be organized

Emphasize good housekeeping throughout the facility. Make sure equipment in all areas of the facility is in good working order, everything is in its designated location and properly labeled. Keeping all areas of the facility neat and organized helps minimize the potential for accidents and will create a good impression.

Having your paperwork in order is just as important. Be sure all your records, training documentation, permits, and other documents are organized and readily accessible. One of the first things an inspector will do during an inspection is request to review your records, including permits, required monitoring and recordkeeping information. They may also ask to review a facility map. Remain diligent in making sure you have well organized and accessible records.

Have a plan for inspection day

Make sure you have a team ready to handle any agency inspection. Team members should be courteous, professional, trained in what to expect, and know their role in a successful inspection. Being prepared and organized will help move the inspection along as quickly as possible.