Tuesday, November 4, 2008

Environmental Compliance Assessments - Quality Assurance in Day-to-Day Assessments

“The EHS manager for a large facility arrives at work to find an agency inspector looking to review his hazardous waste storage area. He accompanies the inspector on the tour and, along with the inspector, discovers numerous deficiencies in labeling and storage practices. He spends the remainder of the morning in a conference room with the inspector going over the deficiencies and discussing potential Notice of Violation and fines.

Upon return to his office, the EHS manager finds on his desk the weekly inspection report for the hazardous waste storage area, completed just after the inspector’s review.

The weekly inspection report indicates No Issues, as it does each week”

This story is true. In this case, upon further review, it was discovered that the staff from the department given the responsibility to conduct inspections were given no training on what the regulations actually required. Although inspections were being conducted as scheduled, the results were providing no value to the organization.

Various types of inspections and compliance assessments are conducted at most facilities to comply with regulatory requirements. Inspections are often required under hazardous waste regulations, SPCC requirements, wastewater permits and other types of permits. These “day-to-day” assessments are no less important than formal facility audits or compliance assessments, yet some organizations put much less emphasis on assuring their quality.

Recent regulations are becoming much more specific about who within the organization should or can conduct these assessments. This is based on two primary factors:

Experience – what are the minimum qualifications required for staff conducting compliance assessments?, and
Training – what training is required to demonstrate that staff meet these minimum qualifications?

Some of the regulatory requirements are very specific in this regard. For example, in New York, only “qualified staff” can conduct routine facility stormwater inspections. Qualified personnel are “those who possess the knowledge and skills to assess conditions and activities that could impact stormwater quality…, and who can also evaluate the effectiveness of BMPs.” In addition, qualified staff must also be trained in accordance with the State’s requirements.

To address these constraints, organizations need to 1) evaluate their “pool” of staff available to conduct inspections, 2) determine which individuals meet the minimum requirements, and 3) provide the required initial and reoccurring training.

By becoming more systematic, organization can be assured they meet their regulatory obligations. More importantly, they can also be assured that their “day-to-day”
efforts to assess compliance provide reliable results and actually reduce regulatory liabilities.

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