How to Prepare for a RCRA Hazardous Waste Inspection
To help you develop a comprehensive standard operating procedure (SOP) for RCRA inspections, here we lay out the crucial inspection elements: site readiness, procedures for handling the administrative audit and the physical inspection of the premises, how to conduct a post-inspection consultation, and appropriate responses to enforcement actions.
The RCRA Inspector Arrives
While you probably won't be expecting an inspector—the arrival is often unannounced—the environmental inspection itself will follow a predictable procedure. The steps of a normal hazardous waste or other EPA inspection include:
- An opening conference for introductions and setting the parameters for the inspection;
- A review of records;
- A "walk-around"; and
- A closing consultation to discuss findings.
Before the Inspection Begins
Your EPA inspection SOP should identify the company representatives responsible for handling regulatory inspections. Personnel in your reception area must be familiar with procedures for verifying the inspector's credentials and addressing security measures. In addition, appropriate guidance and personal protective equipment should be available to keep the inspector safe.
Many sites find it helpful to have an inspection "kit" at the ready, containing a flashlight, tape measure, camera, and other items. A site map indicating the location of satellite and central hazardous waste storage areas can keep things organized.
Do your employees know how to interact properly with inspectors? If there are doubts here, it may be an element you want to add to your internal RCRA training curriculum.
The Administrative RCRA Audit
Know the location of records and ensure they are quickly available. Are your "t's" crossed and your "i's" dotted? Take the time to ensure your training and shipping records are in order. The inspector will likely scrutinize your waste identification and land disposal restriction (LDR) documentation, reports, Hazardous Waste Manifests, and contingency plans.
Maintain a professional demeanor during the process. Good two-way communication is imperative: answer truthfully and ask for clarification and regulatory references. Take notes and duplicate samples. For example, if the inspector snaps a photo of a piece of equipment, a container, or a hazardous waste storage area, a best practice is to snap an identical (or near identical) photo. This way, you know your records are in line with what the inspector is bringing back to his or her office.
Finally, once the site walk-through is completed, a de-briefing takes place during which the inspector will ask any final questions, provide additional information, and review preliminary findings. During the consultation, you might agree on several immediate corrective actions and firm up follow-up steps. The inspector can help you understand the enforcement and compliance process. Expect a report that may include time-sensitive formal and informal requirements.
By knowing what to expect when a State or Federal inspector arrives at your site, you will be well on your way to achieving high marks for compliance during your next inspection. Use the tips above to make sure everyone at your site knows their responsibilities during inspections and what to do when an inspector shows up, even if you don't see it coming.
Free White Paper: Mastering RCRA Inspections
For additional information on this subject, Lion Members can access the white paper Mastering RCRA Inspections at Lion.com. Forgot your Lion.com Member username and password? You can request it on the log-in page.
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To help you stay up to speed with new and changing RCRA rules for 2017, Lion will present the Hazardous/Toxic Waste Management Workshop in a city near you soon. Know what to expect from the soon-to-be-final Generator Improvements Rule, get up to date on electronic manifest fees and requirements, and build the confidence to make big decisions that keep your site in compliance with the RCRA rules. See the full schedule and sign up now!
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