Within the last five years, EPA Region One inspectors have investigated 2420 facilities for environmental health and workplace safety. Last year, 349 facilities were assessed to be in violation of the Resource Conservation and Recovery Act (RCRA) law and fined. 185 people were criminally charged in 2015. 129 years of jail time were meted out. This is just one example of the importance of being prepared for EPA inspections.
What to Expect with EPA Inspections
When the EPA inspectors arrive they do not need a warrant. It is usually a surprise inspection that requires a walkthrough of your facility and gives you no preparation time to label containers or find old manifests. You can possibly deny entrance but they will issue a Denial of Access notice and that opens the door for anything and everything…including ATF and OSHA. They would probably pursue a restraining order, and request Sheriff or State Police assistance within 24 hours. If you start off being negative toward the inspector, it will automatically be a hard road for you.
If, however, you are well versed in DEP, OSHA, and EPA audits, then you probably have all of your ducks in a row. You will know exactly where the file is for past hazmat shipments. You will know where your eyewash and emergency showers are. If they ask about haz mat storage you will get your key for the shed locker. When employees see what is happening they won’t mysteriously disappear.
Inspections may be completed by one or more people, and take one or more days. This walkthrough is conducted as a cursory overview of the environmental state of your facility and how it impacts your workers. Things that inspectors topically key upon are general housekeeping. Are your workspace and that of the hazardous materials area messy? Are people responsible for a specific area? Do those people know their responsibilities?
MLi Environmental audits your lab, school, hospital or facility prior to DEP, DEC, EPA, and OSHA walkthrough. We draft a comprehensive report based upon our findings and present that to your top-level managers. In doing so we preempt any federal and state inspection for hazardous chemicals and waste materials. The federal inspector sees you are taking the initiative and using a 3rd party auditor so the results are not biased.
To learn more about EPA inspections and how to be prepared, contact the team at MLi Environmental today to speak with the experts.