While at a client site yesterday, I received a call that the Fire Department wanted to visit the facility. About an hour later a representative from the local fire department was on-site. Believe it or not, he wanted to see the chemicals reported on the Tier II report for the facility submitted earlier in the year—as discussed last week the Tier II report is due by March 1 of every year. A practice that I have made a habit of is the creation of a documented evaluation of all materials present at a facility that are listed as Environmentally Hazardous Substances (EHS)—I also conduct this evaluation for any required regulatory reports. The practice makes is much easier to explain to a regulator the reason for reporting or not reporting a specific chemical while greatly reducing questions and potential findings.
It is not only important to create adequate reporting documentation but also to file it in manner that makes it easy to locate in the event of an unannounced inspection. Initially I was unable to find my files—needless to say this caused a bit of a panic—however, shortly after the inspector arrived I found the file and was able to provide him with the requested information and to correct some inaccuracies. In addition to my calculations he asked for a site map, the location of all materials that were reported on the Tier II report, the facility’s emergency response plan and a list of emergency contacts. This inspection points to the need to be prepared with documentation required by regulations applicable to your facility. It also highlights the need to ensure communications about the location of such documentation. What happens when the consultant or EHS professional is not on-site? These scenarios should also be considered and plans created to address them. Had I been unprepared or unable to locate the documentation, or if the client was not knowledgeable about the location of the files had I been off site, the facility would have most likely been cited and possibly fined for not meeting these requirements.
Are you prepared for your next unannounced inspection? Do you have a practice that works in maintaining good records? Please share by leaving a comment.