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Environmental Compliance Inspection Course Facilitators Manua

Inspection Planning 6-

Environmental Compliance

Inspection Course

Inspection Planning

From your own experience or the anecdotes described below, tell the group some horror stories

about the results of inadequate planning. Then ask the group to discuss examples of cases inwhich they were unprepared and the results, including how they handled the situations.

Do you know who Murphy is? He wrote, "Murphy's Law which applies to inspections as well

as everything else:

"If anything can go wrong, it will."

You should always plan for your inspections to prevent the worst from happening:

An inspector entered a facility to conduct a "routine" inspection for PCBs. Once

inside, he came upon some smashed capacitors, sitting in a puddle on the ground. The inspector

had his sampling equipment with him, but had left his camera in his car. He went out to get the

camera to document the spill, but when he reentered the facility, the capacitors had been swept

up, and the puddle was gone.

An inspector was taking a sample of a sewer discharge. He failed to put his

container away on a windy day and it blew down the open access into the sewer system. When

he tried to retake the sample, the inspector discovered that he had not brought any extra

containers with him.

What are some of your experiences? Have any of you had things go wrong during an inspection

because you didnt anticipate something or came poorly prepared?

Session 6: Inspection Planning

Time: 1 hour

Equipment: Projector for slides

Preparation: Study NotesThink of Anecdotes

Handouts: None

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2

Planning the Inspection

Q Importance of planning

Q Key planning activities

Q Project plan

Defining scope and objectives

Review facility records

Planning and preparation are important to:

Focus the inspection on key issues

Make the most efficient and effective use of the time spent on site

Ensure that equipment, transportation, and other needs will be available

Ensure that proper procedures are followed

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Be Prepared!

This is a photograph of a wood product plant where they make pressed plywood. As you can see,

it is not the cleanest operation, and there are multiple sources of pollution. Where would youbegin your inspection? What hazards may exist on the facility that could put you in harm? What

questions are you going to ask? You need some sort of plan of attack so you can conduct the

inspection in the most efficient way.

What are some planning activities you can think of doing before an inspection?

Ask the group to suggest important planning or preparation activities that should be conducted

before going to a site for an inspection and to discuss briefly the importance of each activity. List

them on a flip chart. At the conclusion of the discussion, the list should include at least the points

shown below.

Understand the objectives of the inspection and know what the specific areas are

to be inspected

Arrange logistics, including travel to and from the site, any special travel needs,

and hotel accommodations

Identify any special monitoring or analytical equipment needed and arrange to

procure it

Review available records to become familiar with the facility

Assemble materials and equipment Prepare QA/QC plan and safety plan

Coordinate activities with supervisors, attorneys, state agencies, and others, as

appropriate

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For complex inspections, we will list all these elements in a written Project Plan. The plan should

include a discussion of :

Objectives of the inspections

The background of the facility

What Tasks you hope to accomplish during the inspection

What policies and procedures you and your inspection team must follow

Any safety concerns to ensure you come back from the inspection unharmed

Any resources you will need such as people, funding, cars, etc.

The schedule for the inspection when you will begin, and when you will present the final

report.

I will discuss each of these elements in detail.

4

Elements of a Project Plan

Q ObjectivesQ Background

Q Tasks

Q Policies and procedures

Q Safety

Q Resources

Q Schedules

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A first step in planning is understanding why the inspection is to be performed:

Reason: routine, for cause, case development support, follow-up

Scope: specific regulations

Depth: walk-through, records review, sampling, observation

Topics: specific control and treatment systems, records, self-monitoring,

contingency plans and emergency plans, employee training

Also, determine what is the successful outcome of the inspection. In some cases, you may be

there to check the overall performance of the facility, while in others, you may be investigating a

particular release or environmental problem.

How do you decide which facilities to inspect and when? Solicit responses and discuss different

targeting methodologies.

You should determine why the facility is being inspected. The reason it was selected can

influence how you conduct your inspection.

5

Identify the Overall ProjectObjectives:

Q Focus on why the facility was targeted Reasons for selecting the facility

Q Determine the desired outcome

Create a statement of objectives

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Gather BackgroundInformation:

Q Background information is critical forthe development of a project plan

The inspector should review your agencys records to:

Become familiar with the type, size, and operations of the facility

Discover inadequacies, inconsistencies, or voids in the information, thus determining the need

to request additional information from the facility

Minimize inconvenience to personnel of the facility or unnecessary use of their time by not

requesting information that EPA already has

Clarify technical and legal issues before entry

You should develop an appropriate inspection plan that documents this information and applies itto shaping a methodology for the most efficient use of inspection time and manpower resources

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Review Facility Information

The inspector should look for facility information such as

Diagrams, and photographs

Special entry requirements

Process operations and production levels

Control equipment

Record keeping systems

Safety requirements

Permits, permit applications, and special exemptions

Prior inspection reports and reports on enforcement actions

Self-monitoring reports

Laws and regulations

Technical reports relevant to processes and contracts.

REMEMBER: It is better to know all and play dumb than to know nothing and BE dumb.

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Facility Map

When you are inspecting facilities with multiple buildings or units, you should try to get a map

or plan for the facility. This might be found in previous inspection reports or other files in youragencys office, but you may not be able to find one until you actually get on the site.

This is less important at smaller facilities, since it is easy to find your way around. However,

even at smaller facilities, some type of floor plan or map can be very useful as a guide for your

notes. You will be able to show what areas you visited, the location of different pollution

sources, and where you may have taken samples.

A map, such as the one here, can also serve as an important piece of evidence as you explain the

violations or impact of the violations in a court. It can help others better understand the layout ofthe facility.

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Your project plan should list each task or activity that must be accomplished to meet the

objectives of the inspection. Some of these will be the same for any type of inspection, but therewill be some variation depending factors such as whether or not you intend to sample, what

specific areas of the facility you want to visit, and what environmental media you are concerned

with.

You should also list what specific questions you need answered or areas of focus. This may

include areas of the facility you need to observe, or people you need to talk with. Many of our

inspections are the result of a complaint from a neighbor or another concerned person. You

should specifically list a review of those issues as part of your list of tasks.

Identification of Tasks

Q What activities MUST be accomplishedto meet the objectives of the inspection

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Inspection Planning 6-1

You need to be aware of any special procedures your agency may impose on you during the

inspection. Some of these may come from agency policy, while some may be mandates from thelegislation. They may vary depending on the scope and purpose of the inspection. For example, in

the United States, one of our environmental laws requires that inspectors obtain a written statement

from the facility giving permission to inspect. However, the other environmental laws do not have

this requirement, so an oral authorization is adequate.

Another issue to resolve before beginning the inspection is whether or not to tell the facility you are

coming before you arrive. Lets talk about that for a minute. Who thinks you should call ahead of

time and make an appointment? Who thinks you should show up unannounced? Take a vote.

Alright, lets make a list of the Pros and Cons of announcing your inspection.

Using a flip chart, ask for at least 5 pros and 5 cons for announcing the inspection ahead of time.

Typical suggestions include:

PRO CON

Proper people will be present Facility can clean up quickly before inspection

Documents will be collected for review Documents may be altered to hide violations

Easier to schedule activities Plant may shut down to hide poor operations

Quick cleanup doesnt hide real problems Unlikely to get accurate picture of daily activities

Safety concerns identified Some operators may be isolated

You may also need to notify other regulatory agencies. In the United States, the Federal EPA can

conduct inspections, but we share that authority with our states through annual agreements with

them. These agreements often outline the terms for EPA inspecting when the primary regulator is in

the State. This may also occur with local governments, or even police. Be mindful, and make sure

everyone that needs to know, knows.

10

Policies and Procedures

Q Special procedures applicable tothis inspection

Notification of facility prior to inspection(Announced or Unannounced)

Notification of other local regulatoryofficials

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This course will not cover your health and safety concerns very much at all. However, we do

believe that it is an extremely important topic, and one you should think about continually as youprepare for and conduct your field work. In many cases, the very nature of our business is

dangerous and requires extra care to stay safe. Many of the chemicals that pollute our

environment are regulatory concerns because of their toxicity or risks, so every time you are near

these chemicals you are putting yourself at risk. In other situations, there may be physical risks

from machinery or activities at the sources we are inspecting. Pay attention.

Your agency or other agencies may have specific requirements to keep you safe as you do your

job. For example, in the United States, the Occupational Safety and Health Administration, a

completely separate agency from the Environmental Protection Agency, sets the standards for

worker safety. One of those standards applies for inspectors, and requires us to attend up to 40hours of health and safety training before we can go on a site with hazardous materials and 8

hours of refresher training every year. If your subject to similar requirements, make sure you

follow them.

As part of your inspection planning, you should develop a Site Safety Plan. This plan should

identify potential hazards at the facility and how you intend to reduce your risks to an acceptable

level. It should also specify what type of equipment you need to protect yourself. What type of

safety equipment do you have available? How many of you have hardhats? Steel toe shoes?

Respirators?

What should you do if you are presented with a condition that you do not have the equipment to

handle, for example, an area with high levels of toxic chemicals in the air with no respirator? You

should avoid the situation your health is more important than the violation.

11

Safety Plan

Q Requirements of specific organizationQ Safety equipment required

Q Special safety considerations

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12

Know what kind ofhazards you are

dealing with!!

Safety !Be Prepared!

The main thing to keep you safe is to understand what the hazards are so you can avoid them.

This picture is from a landfill full of drums of unknown material giving off some type of fog. Aswe later found out, this fog was highly flammable, and could have lead to an explosion if any

spark or source of ignition was present. If we had charged right in assuming it was not

hazardous, we could have easily blown ourselves up, as well as everyone within hundreds of

meters.

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Your inspection plan should outline everything you will need for the inspection including people

and expertise. You should list who will be going on the inspection, including yourself, and ifany additional support will be needed. This document may be used by management to allocate

resources, so you should clearly spell out what you need. Depending on the scope of the

inspection, you may need more or less people.

You should also list any laboratory support you will need, and contact the laboratory before you

go. Laboratories dont like samples that arrive at their lab unannounced, and you should let them

know what to expect. We have lost cases where laboratories received important samples but

were not able to process them quickly enough to use the results. In other cases, samples were

sent to a laboratory that did not have the capability to test for the particular contaminant of

concern because the inspector did not check with the laboratory on their capabilities prior tocollecting the sample.

Finally, list any other supplies or support you will need. You should include an estimate of the

cost of the inspection, both in terms of travel expenses and time.

13

Resources

Q Team members for onsite inspection Number of inspectors

Sampling team

Q Laboratory support

QAdministrative support

Q Money

Q Time

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Your inspection plan should specify when certain milestones will be reached before, during, and

after the inspection. These should be agreed to by all members of the inspection team andmanagement. You should set a date for meetings prior to the inspection, the dates of the actual

inspection itself, and dates when the inspection report will be finished. In some situations, you

may have different people writing different parts or sections of the report. When that happens,

you must have a due date or they will put things off and never finish the product. While there

may be some uncertainty due to outstanding information such as sample analysis results, you

should have projected or target dates.

14

Milestones inSchedule Development

Q Schedule Date for the pre-inspection planning

meeting

Date of the inspection (on site)Q Opening conference

Q Closing conference

Dates that the reports are dueQ Draft report

Q Final reportAPRI

L

7APRIL

97

APRIL

8

APRIL

7

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Final Pre-Inspection TeamMeeting

Finally, if more than one person is going on the inspection, you should have a meeting with

everyone going to the facility. This gives everyone the chance to share any information theyknow about the facility with the group and for each member of the team to discuss their strategy

for the inspection.

Also, it helps you form a true team. You will need to work together during the inspection, and

building a rapport with everyone helps. In some cases, inspectors may come together from

different locations or programs to conduct the inspection. It is much more effective if they meet

each other before they arrive on the facility.

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Inspection Planning 6 1

In your notebook, Ive included an Inspection Planning Checklist that runs down through

everything Ive said on a one-page form. Even if you are going on an inspection at a fairly simple

facility, it is worthwhile to at least go through this checklist in your mind to make sure you

havent left anything out of your planning. Read through the checklist as summary.

GENERIC INSPECTION PLANNING CHECK LIST

OBJECTIVES

What is the purpose of the inspection?

TASKS

What records, files, permits, and regulations will be checked? What coordination with laboratories, other programs, attorneys, and state or

local governments is necessary?

What information must be collected?

PROCEDURES

What specific processes of the facility will be inspected?

What procedures will be used?

Will the inspection require special procedures?

Has a QA/QC plan been developed, and is it understood?

Has a safety plan been developed, and is it understood?

What are the responsibilities of each member of the inspection team?

RESOURCES

What personnel will be required?

What equipment will be required?

SCHEDULE

What will be the time requirements?

What will be the order of inspection activities?

What will be the milestones (What must be done, compared with what is

optional?)