Top 5 Tools For When a Regulator Shows Up
Top 5 Tools For When a Regulator Shows Up
Sara R. Hamidovic, MS, PE, CHMM – President; Elizabeth Grubb, MS, MPA – Storm Water Program Manager
We hope you all are staying cool and enjoying the end of summer! As we all know, the Coronavirus Disease 2019 (COVID-19) has impacted businesses all across the country over the past two years. Just like all of us, the way environmental regulators do their jobs changed. In many states regulatory inspections slowed down or completely stopped during the height of the pandemic. However, inspectors are hitting the road again across Illinois. Therefore, today we wanted to cover some tips and tricks for regulatory inspections. We hope this article provides you with some helpful hints to come through your inspection smelling like a rose!
1) Treat inspectors in a welcoming and professional manner.
It’s important to start off on the right foot and set the tone for a positive interaction – shake off any anxiety, be confident, and be courteous! Welcome the inspector to your facility. Introduce yourself and other managers and employees nearby. Ask for the inspector’s name and the agency and department they represent (get a business card, if possible). After introductions, kick up a little small talk to ease any tension by asking how the drive was or what city they are from. When the clipboards come out and the inspection begins, don’t take offense to any noted deficiencies or recommendations. Be polite and accommodating to ensure the inspection goes as smoothly as possible and the inspector leaves on a positive note.
2) Don appropriate PPE and provide it to the inspector, if necessary.
Before you head out to working areas, be sure you’re wearing your PPE. For typical recyclers this may include a hard hat, steel-toed boots, safety glasses, gloves, and/or reflective vest. The inspector should also wear PPE – keep a clean set (or two) in your office on the off chance a surprise inspector doesn’t have their own. This shows the inspector that you are dedicated to safety at your facility.
3) Take notes and be responsive.
It’s important to show the inspector that you value what they do and want to benefit from the inspection. Follow the inspector as they complete their inspection and answer any questions they may have. Provide honest and definite answers without adding extraneous information. Avoid speculation on anything you do not know for sure. If you cannot answer a question, tell the inspector you will look into it and get back to them in a timely manner. Take notes on what the inspector observed and any comments made. If the inspector seems open to discussion, ask them if they have any tips or recommendations and jot down any helpful notes. During the conclusion of the inspection ask the inspector any remaining questions you may have. At this time, it is a good idea to ask the inspector to summarize their findings. Please note that the inspector may not be obligated to provide you with an inspection summary before they leave and you may have to wait for a written report. In taking notes and being responsive, you show the inspector your willingness to improve and act on noted deficiencies.
4) Violations are fixable. An inspection will not lead to the downfall of your business. Inspectors are human. Their goal and your goal are mutual: to fix the problem and move on. Regulators don’t expect businesses to be perfect all the time, and they don’t expect compliance to suddenly happen overnight. What they do expect is respect, an honest effort by your company to fix noted problems, and work toward compliance. Be sure to maintain communication with the agency throughout the process and respond to all communication in a timely manner. Do NOT ignore them. They will not go away and ignoring them could result in fines or drawn-out enforcement action that was not originally intended. When you work with the agency instead of against it, it shows that you genuinely want to fix the problem and puts your business in a favorable light.
5) Always be prepared. Keep records handy. You should be able to readily access certifications, training records, your company’s salvage license and business permits, your storm water and spill prevention plans, and any records of waste material disposal. Not only is it beneficial to have these in a crisis, but it also shows the inspector that you care enough about your business practices to keep and maintain your records. This is a great time to make sure your facility’s paperwork is up to date!
Finally, you are never expected to go it alone. When in doubt, contact us. We can be reached by email at info@vet-env.com or by phone at (812) 822-0400.
Got Compliance?