Facilities that store chemicals and other hazardous substances are subject to numerous rules and regulations. These guidelines are established by government mandate or private industry groups utilizing industry best practices, and are generally established to provide for a safe working environment and to protect human health and the environment. Representatives of the local, state or federal environmental regulatory agencies may arrive at your doorstep for an unannounced environmental compliance inspection. Having an understanding of your requirements and a working knowledge of what to expect during an inspection may allow you to avoid unnecessary stress and possibly avoid a citation or fine for violations. Every facility is different, and the requirements for a warehouse, retail petroleum fueling station and chemical production facility will all be different. Additionally, depending on the agency and personnel conducting the inspection, the extents and objective of an environmental compliance inspections will be very diverse. Point to Point Environmental can be your resource to prepare for an inspection by assisting you with an audit of your facility, reviewing the applicable regulations that may apply, and making the necessary preparations.
There are numerous reasons that may trigger an inspection by an environmental regulatory official. Regulatory agencies often have internal requirements to conduct a certain number or percentage of facility inspections per year. These ‘quotas’ can be mandated by new laws such as the 2005 Federal Energy Act which also included additional funding to state regulators to assist with inspections of Underground Storage Tank (UST) facilities. An inspection may be started by initiation of a new permit application or a follow-up inspection for past permits and/or violations. Additionally, a citizen compliant or employee injury may result in a visit from an environmental regulator. Point to Point Environmental will assist you before an inspection ever occurs by performing background file research and review, and meeting with you to review your facility’s plans and permitting requirements.
Environmental regulatory agencies and their office and field inspectors have the legal authority to request information and records or to enter a facility to perform an inspection. You may or may not be notified in advance of an inspection, though most facility inspections are not pre-arranged. Regardless of the instigating factors for an inspection, effective communication with the inspector is the most important feature when beginning an inspection process. Point to Point Environmental specializes in regulatory interface on behalf of our clients, and we have experience communicating with inspector regarding your questions and concerns about the reasons and the process of an inspection. If prior notification is provided, Point to Point environmental will assist you with a preliminary audit and coordinate the inspection so that you and your facility are prepared and the inspection is conducted at an appropriate date and time. Inspectors understand that you may have concerns about proprietary information and confidentiality issues, and they understand that you ultimately intend to operate a facility that is conducive to a profitable business. Therefore, opening an inspection process with an amenable dialogue via telephone call, informal discussion or formal meeting as is appropriate will pave the way for effective and productive discussions in the future.
You and your employees are the most knowledgeable assets to facilitating an efficient and thorough inspection process. If you employ an environmental and safety officer who has the firsthand knowledge of your facility and the proper safety procedures, they should always be involved during these initial discussions. Additionally, long-employed maintenance teams or administrative staff may have the most intimate knowledge of your facility operations including layout and processes, document management and safety records. Environmental regulators have standard forms that they may use when completing an inspection of your facility, and they will have lists of the required records and the data that they need to collect during an inspection. An inspector may ask to have copies of your records provided to them at the time of inspection, and they will take copious notes of all they observe during the inspection. Contact information for all employees and staff that assist or participate within an inspection will be an important part of the final report.
When you partner with Point to Point Environmental beforehand, we can assist with developing a process to maintain your environmental records in an organized manner so that they are readily accessible in the event of an inspection. Our experience with regulatory compliance will facilitate a timely completion of an inspection, and improve your ability to satisfy an inspectors’ recordkeeping requirements. Inspectors may request up to 3-5 years of past records in addition to your current records. An inspector may provide a list of additional records to be submitted, and Point to Point Environmental staff can assist you with compiling the necessary information and communicating these requirements back to the regulatory agency. It is possible that some of the records requested documents are not currently available or utilized by your facility, and Point to Point Environmental can assist with acquiring and creating the necessary documents for your facility’s long term use.
Following the preliminary site meeting and records review, the inspector will conduct a physical examination of your facility. The physical tour of your site is the main tool that the inspector will use to gather information about your location and its operations. All environmental aspects of your facility should be a part of the inspection. Point to Point Environmental can be present at your property to assist with an onsite facility and equipment inspection. The inspector will examine the facility processes, system components, waste generation and storage, air and water emissions, wastewater management, chemical storage, and permit requirements. An inspector may ask questions and you or your staff may not know the answers. While it is important to provide accurate answers to the best of your abilities, if you do not know the answer it is better to be honest with an inspector and make the efforts to provide a response at a future time. Point to Point Environmental can assist you with researching the required data so that we can properly answers an inspector’s requests.
Inspectors from environmental regulatory agencies have the legal authority to take photographs and collect samples from your facility such as soil samples, wastewater discharges, waste materials, or air emissions samples. If the inspector plans to collect any compliance samples, it is important for you to conduct sampling at the same time. Point to Point Environmental can assist with collecting duplicate or spilt samples concurrently with an inspector and to have them analyzed at an accredited laboratory. Additionally, Point to Point Environmental will discuss the reasons and procedures with the inspector during the sampling, and carefully document the sampling activities and ensure that the proper chain-of-custody procedures are followed. Collection of split samples is an industry standard practice to ensure the validity of the sampling results.
Finally, at the completion of a physical site inspection, the inspector will discuss their findings with the appropriate facility personnel, and the inspector will leave instructions for repairs or corrections that may be required to processes, storage, spill prevention systems, etc. An inspector will often complete a site inspection, leaving a checklist specifying the additional requirements to be completed. The importance of correcting these issues and transmitting the supporting documentation cannot be minimized. Failure to promptly complete these activities may result in a violation and fines. Additionally, violations regarding any shortcomings in your site’s compliance may also result in denial of future permits and higher insurance premiums.
In addition to assisting with preparation and compliance during an inspection, Point to Point Environmental can assist you with developing a self-assessment program at your facility. While it is important to get through an inspection process, Point to Point Environmental aims to assist our clients to ensure that you are complying with all environmental requirements in the future to avoid costly violations and fines. The implementation of a site specific self-assessment plan for your facility can reduce your compliance costs over the long term. Contact Point to Point Environmental today at 678-565-4440 to discuss your facility’s needs and to begin the process of developing a plan for a successful compliance inspection.