Linebach Funkhouser, Inc.
Surprise!… Inspection: Ten Tips for Handling Environmental Inspections
It is Monday and you are in the beginning of the weekly routine of production meetings, operation schedules and to-do lists. Then surprise… an environmental inspector arrives at your facility! Now what? The following pointers for dealing with surprise inspections may be helpful:
Number 1 – Remain calm. Your first reaction might be to panic, but don’t! It is ok to be nervous, but remember that you can always practice inspections with management or consultants. (Hint: It’s a good idea to conduct internal audits on a routine basis and to have various members of the sites’ team participate so that they understand what may be expected of them during a real inspection!)
Number 2 – Ask for Identification or a business card. This might sound like a no brainer, but if it is a new inspector you will want to document this for your records. (Most inspectors will show their State Agency issued badges or will provide a business card upon arrival)
Number 3 – Identification of lead person. Communicate to the inspector that a certain person will be the overall contact during the audit. The key individual (normally the site’s EHS Manager) will be generally responsible for dealing with the inspector, providing follow-up information, and filing the necessary internal reports/documentation associated with the inspection. The office administrator or secretary and others in the plant front office should be informed of a set procedure to follow and whom to contact when an inspector arrives. Also, have a back up person in place because you never know when you might need them.
Number 4 – Expeditious Review. Most regulations and guidance will stipulate that ‘expeditious review’ of records and documents should be available. This means that you cannot ‘stall’ the inspector with gobblygook in the front lobby. When they show up, it’s time to let the rubber meet the road and get going. If you need to call in an external resource, it’s always a good idea to do that before you head to the lobby to meet the inspector. Further, explaining to the inspector that someone else will be assisting, if that’s the case, is a good idea. Kick the inspection off with a ‘kick-off’ meeting to establish the who, why, what, and where that the inspector is expecting to accomplish.
Number 5 – Plant Tour. Plan the plant tour very carefully! The inspector will probably ask to see equipment in operation. You are in the “tour guide” so take the most desirable direct path to the specific equipment.
Number 6 – Show only requested information. Many large corporations have internal policies to provide only data that is requested; nothing more. LFI recommends maintaining different binders for the air, water and waste (or other media where you may be inspected). This method will allow you to be in control of the data that the inspector sees and reduces the risk of potential record NOVs. (HINT: Computer documentation is often beneficial however, it can be a bombardment of data on an inspector. Be sure to establish that you’re providing the data that the inspector is seeking to avoid potential problems).
Number 7 – Photographs. The inspector might request to take digital photographs of equipment, processes or other related items during the inspection. It is important to know your company’s policy on photography in the plant. If you allow photography in the facility, request copies of all photographs in the inspection report (remember though, the inspection report is publically available so, if sensitive information/data is contained within the pictures, you may wish for them to be separated and marked confidential – or disallow pictures all together).
Number 8 – Inspection Documentation. There is an old saying that everyone has 20/20 hindsight. After (and during) the inspection, take specific and plentiful notes! Document important things like the inspector, date, equipment visited, and records reviewed. Also note how you think you did and areas for improvement. Taking notes is one way to improve the next time.
Number 9 – Inspection Summary. Often the inspector will provide a “pink copy” of the inspection notes to you. If not, you might want to ask the inspector for a verbal summary of the inspection. Inspectors will usually describe the good and the improvement areas of your facility. Better yet, see if he/she will allow you to copy his/her notes on the photocopier.
Number 10 – Inspector is a Person. Remember, the inspector is there to do a job and the inspection shouldn’t be viewed as an ‘us versus them’ death match cage fight. It can be very challenging at times to work with inspectors, but it is important to remember that they are a person too! You probably will be working with this person for months and years to come and the relationship that you form with them does impact inspection conditions when they arrive. Relationships are tough to establish at times, but in the long run, it’s our experience that a strong and open relationship with the site inspector will go a long way in making an inspection more simplistic and will, overall, benefit the facility (and your sanity during the inspection).