A presentation at the 2015 Midwest Environmental Compliance Conference, May 13-14, 2015, Overland Park, KS

1. Coping with Environmental Agency
Inspections
Before, During, and After
Jerry P. Bauer, P.E.
Burns & McDonnell Engineering Company
May 2015

2. Agency Inspections
Environmental Inspections are like…
Taking a test

3. Agency Inspections
Your fate is determined (primarily) prior to the inspection
(test)!

4. Environmental Agency Inspections
What to do…….
• Before the inspection
• During the inspection
• After the inspection

5. Before the Inspection
► Make sure your Facility…
►Is in Compliance with ALL
Environmental Requirements!!

6. Before the Inspection (What to do)
Develop an “Environmental
Regulatory Inspections” Policy
►Define Company Policies and
Procedures Associated with
Managing Environmental Agency
Inspections
(Guide the person in the hot seat
when the inspector shows up).

7. Before the Inspection (What to do)
Advantages of Having Written Policy
►Quick Reference Guide (especially if regular
contact is absent)
►Support Environmental Coordinator in taking hard
line
► Uniform Company Position/No Second Guessing

8. Before the Inspection
ORGANIZE ENVIRONMENTAL RECORDS
Advantages of Well Organized Environmental Records
1. Able to Provide Requested Records
2. Avoid Providing too Much Information
3. Get Inspector Out the Door
4. Appearances Count

9. Before the Inspection
ELIMINATE LOW HANGING FRUIT
Example of Low Hanging Fruit
Spent Fluorescent Bulbs -
► Containers not
dated/closed.
► Obvious Universal waste
violation.

10. Before the Inspection
Examples of Low Hanging Fruit
► Poor Housekeeping/
Oil spill
“Bad Appearance”

11. Day of the Inspection
Quickly Review Company Policy and…
► Verify Inspector Credentials
► Inquire about purpose of inspection/request inspector documents
►Notify (Plant manager, attorney, etc)
► Set up in dedicated conference room
► Confirm Ground Rules (No photos, escort at all times, etc.)

12. Day of the Inspection
Walk-Through/Plant Tour
►Show Auditor requested area (no more)
►No Safety Shortcuts
►Straight line to requested areas

13. Day of the Inspection
Inspector Interviews
► If Inspector asks to interview specific person…
► If Inspector request is more general:
• Avoid the “loose cannon”
• Avoid employee with axe to grind
• “Cherry Picking” is ok

14. Day of the Inspection
Records Review
►Put Auditor in conference room
(remote from records)
►Provide records requested;
no more, no less
► Copy and provide requested
records

15. Day of the Inspection
Exit Meeting
► Always a good practice!
► Don’t argue “big ticket items” but correct factual mistakes
► Ask for written report
► Inform inspector if corrected on-site (day of inspection)

16. Day of the Inspection
Issues that Can Be Resolved in Exit Meeting
►Employee indicates he was not trained on SPCC/Storm Water Universal Waste
(but you have sign-in sheet for the class)
►Missing Inspection Records (that you have)
►Container (Used oil) not labeled (inspector did not see)

17. After the Inspection
► If no issues/findings…..
Congratulations!!!!!

18. After the Inspection
If Issues/Findings Identified….
►Consider Pro-Active Response to Audit (Before
letter/Notice Of Violation Received)
►Respond to Formal Requests for Information, Letters, or
NOVs
►Take Corrective Actions to Prevent Recurrence

19. Summary and Recommendations
1. Have a policy in place before the inspection.
2. On the day of inspection:
a. Provide records requested – no extras
b. Answer questions asked – nothing else
c. Show inspector areas requested- no more
d. Being an a**h*** never helps- and can make the
situation much worse
3. Respond Promptly to Inspection reports