Here are some common things inspectors look for when they visit a plant.
Hazardous waste inspections
- Proper labeling of product and waste containers.
- Failure to make a hazardous waste determination.
- Drips, stains, spills and puddles within and outside the facility.
- Illegal disposal of a hazardous waste (e.g. they will look in dumpsters and outside the building before ever knocking on the facility's door).
- Open/closed containers of volatile or hazardous materials.
- Leaking valves and venting systems.
Air inspections
- Improper determination of "potential to emit" VOCs, HAPs, and particulates.
- Pollution control device (PCD) operation records to determine proper operation and evidence that the PCD has been by-passed.
- Open/closed containers of volatile or hazardous materials.
- Leaking valves and venting systems.
Water inspections
- Look into streams and gullies on or near your property, and in drains and man holes on your property in search of evidence of illegal discharges. The inspector looks for things such as flammable vapors, discoloration, and oily sheen in the water.
- Ask to review your NPDES/Stormwater permits and self-inspection records.
- Inquire how the facility determined that an NPDES permit is not required at the facility.
All inspections
All inspectors, including hazardous waste, air, water, or health and safety (OSHA) will look for the following:
- Availability and accessibility of current SDS information.
- Question personnel to determine operator knowledge of hazards and risks associated with chemicals used in the work place.
- Inquire about responsible party's knowledge of regulations.
- Consider your compliance history.
- Can and may request supporting information for regulatory status.
- Seek out the most common violations (e.g. see OSHA's Top 10 Violations list on their web site).