Practical Aspects of Thorough and Effective Inspections

Reasons for Thorough and Effective Inspections

• • •

Identify problems Assess compliance with regulations Evaluate the potential for problems

Pre-inspection Activities

• Define the inspected facility’s processes • Determine the types of products manufactured or produced

• Determine the types of equipment utilized in the processes • Use or raw materials and cleaning solvents

• Determine waste streams • Obtain process flow diagram and plant layout

• Review requirements of permits and permit applications • Determine applicable regulations, limits based on the type of industry or individual operations within facility

• Compliance history ( Caution, not pre-judgment) • Problem areas (Noncompliance history)

• Residential area- potential source of complaints due to odors, visible emissions, fugitive dust and noise.

• Area Surveillance

• Other industrial/commercial sites in area – may contribute or be true source of emissions or odors as part of a complaint investigation.

• Observe and sketch diagram of stack and wall exhausts.

Onsite and Entrance Meeting Activities

• Discuss inspection with involved personnel. • Discuss preliminary assessment of facility based on pre-inspection information gathered.

Onsite and Entrance Meeting Activities (Cont’d.)

• Resolve question related to stacks. Exhausts points, emissions or odors observed and permits.

• Request what information you need for later review (i.e. Raw material usage, material safety data sheets, records regarding compliance or required by permit conditions).

• Finally, “most important” discuss safety issues.

• What types of safety equipment are required or needed ? • Areas of particular caution ?

• Finally, “most important” discuss safety issues (continued).

• Emergency rescue evacuation locations?

• Meteorological (i.e. precipitation, lighting, heat, cold, etc.) related issues for outdoor inspections?

Facility Inspection Tour

• Process-flow tour of facility • Start with receiving and raw material storage (i.e. tank identity, capacity and stored material).

Facility Inspection Tour Cont’d.

• Material preparation areas (i.e.

cutting, grinding cleaning, degreasing, etc.).

• Formulation areas (reactors, mixing vessels, heat treating spraying, lamination, baking coating, etc.).

• Assembly areas (welding, soldering, gluing, etc.) • Product storage, loading and packing • Identify waste streams

Facility Inspection Exit Meeting

• Discussion of inspection observations • Resolve questions regarding exhaust points, observed emissions, process equipment, control equipment, storage activities and detected odors

Facility Inspection Exit Meeting Cont’d.

• Review records and information requested during entrance meeting

• Compare equipment identified on permits with equipment observed during the inspection and resolve differences and the need for additional permit applications

• Conduct one last area surveillance and return to facility to resolve any questions or concerning stacks, control equipment, emissions, odors, etc. and return to facility if necessary

Inspection Report

• Review all the information (notes observations, data, calculations, etc.) gathered about the facility

Inspection Report Cont’d.

• Start with a draft, complete as much of the report as possible, even if all the data is not yet available • Remember the purpose of the inspection in writing the report

• Include other observations, information, findings and conclusions that may not be directly related to original purpose, but which have a direct impact on facility compliance issues

Final Comments

• Remember, the most important aspect of conducting a thorough and effective inspection is to develop an organized plan of approach

Final Comments Cont’d.

• Starting and focal points of strategy is the purpose of the inspection • Avoid tunnel vision; be observant and cover as many aspects of the facility as possible

• Take notes, do not rely on memory of what you have seen, questions you may want to ask and points you want to cover.

• Having notes and diagrams can make a complicated inspection more manageable and effective

Additional Training Resources • U.S. EPA Education and Outreach Group http://www.gov/oar/oaqps/eog • U.S. EPA Compliance and Enforcement h ttp://www.gov/compliance • LADCO http://64.27.125.175/ • Other Consortiums’ Training Courses