With today’s intense focus on environmental regulation and compliance, especially in California, it is standard practice to find yourself dealing with federal and or state regulatory inspections.

Sometimes these inspections will be a surprise. If you are a generator of hazardous waste, The Environmental Protection Agency (EPA) or Department of Toxic Substance Control (DTSC) might show up unexpectedly and ask to tour your facility, review monitoring data, and interview employees.

Now, most companies have longstanding and respectful relationships with state and federal regulators, and certainly never intend to be uncooperative or evasive. A lack of preparation, however, can suggest otherwise. Perhaps not surprisingly, preparation for a surprise inspection is much more important than the proper response to one and should be treated accordingly.

Here is how ESCC Inc. can help your company prepare:

• We will review your California Environmental Reporting System (CERS) documentation to make sure your emergency information is accurate and up to date. This may be one of the first things an inspector reviews upon arrival at your facility.
• We can perform weekly facility hazardous waste inspections of your main accumulation area. We will document and correct deficiencies noted during these inspections. We can also perform monthly inspections of your facility satellite hazardous waste accumulation areas and spill response equipment, documenting and correcting potential violations during the inspection.
• We can provide your employees with the required DOT/RCRA/HazMat and HAZWOPER training. This training will help your employees understand the importance of hazardous waste management, safety procedures and even chemical compatibility issues in your chemical storage cabinets.
• Managing hazardous waste is all about records. We can review training records, write and update Standard Operating Procedures as well as perform mock inspections to ensure your company and employees are prepared, should you receive an inspection.
• Help designate company representative(s) who will be ready to accommodate the compliance officer’s needs and accompany them during the inspection.

Should your company receive an EPA or DTSC surprise inspection, do the following:

• If a compliance officer comes to visit, do not refuse the inspection. Always treat inspectors like ordinary visitors and offer basic safety training before walking the site.
• Far too often, a facility will wait until the EPA or DTSC gives them formal notification of a problem. This is a mistake. If you are aware of problems, correct them. If something could not be located, locate it. If a drum was uncovered, cover it. Unfortunately, deficiencies during an EPA or DTSC inspection will most likely lead to a higher level of scrutiny during the remainder of the inspection.
• If the EPA follows up on an unannounced inspection, finds a violation, and then learns the violation has not been corrected, that violation is likely to result in a penalty. Solid preparation for EPA and DTSC inspections will bring you peace of mind, and dramatically increase your chance of success when one finally comes about. Do yourself and your business a favor and do something about it now.

Contact ESSC Inc. today to schedule your complimentary EHS facility review.