1. Coping with Environmental Agency
Inspections
When the inspector comes knocking!
Jerry P. Bauer, P.E.
Burns & McDonnell Engineering Company
November 2013

2. Environmental Agency Inspections
What to do…….
•Before the inspection
•During the inspection
•After the inspection
56804_United Pumping Services

3. 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).

4. 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
56804_United Pumping Services

5. Before the Inspection
Company Inspection Policy
1.Verify Inspector Credentials
2.Determine Purpose
3.Cameras and Audio Equipment ???
4.Company escort required
5.Records provided to inspector
6.Exit Meeting
7.Signatures on Inspection Form ??
8.Notifications to Plant Manager/Attorney
56804_United Pumping Services

6. Before the Inspection (What to do)
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
56804_United Pumping Services

7. Before the Inspection
Good Housekeeping and Maintaining an
Orderly Facility
•Appearances Count-Chemical spills,
open containers, unlabeled containers
look bad (and may be violations)
•Eliminate the “low hanging fruit”
56804_United Pumping Services

8. Before the Inspection
Examples of Low Hanging Fruit
•Fluorescent Bulbs- Containers
not dated/closed
56804_United Pumping Services

9. Before the Inspection
Examples of Low Hanging Fruit
•Parts Washer Solvent-
Lid not closed
56804_United Pumping Services

10. Facts of Life
Despite Your Hard Work and Preparation…
1.You May be Out-Gunned (Ozone Depleting
Compound/40 CFR Part 82 or SPCC Inspector)
2. Deck May be Stacked Against You (Prevention of
Significant Deterioration (PSD) Review)
3. Success will be highly dependent on the inspector!
56804_United Pumping Services

11. The Inspector
• You know it will be a good day when your
inspector looks like…..
56804_United Pumping Services

12. The Inspector
• You know it will be a bad day when your
inspector looks like…..
56804_United Pumping Services

13. The 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.)

14. The Day of the Inspection
Inspection Components
• Visual/Odor Observation/Walk-Through
• Personnel Interviews
• Records Review

15. Day of the Inspection
Walk-Through/Plant Tour
•Show Auditor requested area (no more)
•Safety training and personal protective equipment
•No Safety Shortcuts
•Straight line to requested areas

16. Day of the Inspection
Inspector Interviews
Examples of employees to interview:
• Boiler operator
• Visible emissions observer
• Refrigerant Technician
• Monthly SPCC Inspector
• Maintenance Personnel
• Leak Detection Inspector
• Operator (Painter, Assembler, etc.)

17. 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

18. 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

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

20. 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

21. 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