What to do When the EPA Comes to Inspect
Things at the plant were going along very smoothly, we were very busy and looking forward to a very successful year, when our state Environmental Protection Agency (EPA) came calling one fine summer day. What should I do when EPA comes to inspect?
Your first thought should be, We are covered since we do everything the right way. If that isnt your first thought, dont panic and just follow the principles listed below. Practice with a mock internal drill in advance. Most importantly, prepare all documents and assemble in a location where all supervisors and managers can find them easily.
- Be truthful in your answers. Do not deny access. Do state whether the persons most qualified to answer their questions are/are not available. Many times the inspectors will come back to meet with a knowledgeable person rather than waste their time.
- Ask the purpose of their visit and which areas they are there to see. Ask what materials they would like to review and take notes.
- Have two people available from your organization present for the discussions, walkthroughs, etc.
- Write down everything asked and every answer provided.
- Take the inspector directly to the area requested. Go around the outside and in the closest door. Preplan your paths and make sure those areas are always well maintained.
- Do not use unnecessary adjectives and adverbs in your descriptions of your building or processes.
- Do not use Resource Conservation and Recovery Act (RCRA) words when discussing materials, procedures, etc, such as spent, discarded, off-spec, used, by-product, and waste. Instead, use words like iron-rich, or contains oil, zinc-rich, inactive, heated, cooled, raw material, input to the process, the output from the process, etc. If you have questions about what to call something please contact the AGA for assistance.
- Review all written documents, signs, instructions, drawings, permit applications, published plans for such RCRA words above and remove or change the references.
- Know your own policies, practices, procedures, programs, and paperwork. Make sure those who should know the procedures actually know the procedures.
- If you do not know, do not make it up and do not keep talking using descriptive terms that may not be appropriate. Do not fill in the blanks for leading questions.
- Remember that no inspector knows your operation better than you.
- Know the laws which govern your processes and materials.
- Prepare a folder with PDF documents of all programs and procedures and records. Keep this folder updated.
- Walk your facility with a fresh set of regulator eyes and immediately fix/change all you see that could be of issue.
© 2020 American Galvanizers Association. The material provided herein has been developed to provide accurate and authoritative information about after-fabrication hot-dip galvanized steel. This material provides general information only and is not intended as a substitute for competent professional examination and verification as to suitability and applicability. The information provided herein is not intended as a representation or warranty on the part of the AGA. Anyone making use of this information assumes all liability arising from such use.