{"id":602,"date":"2012-10-19T05:08:46","date_gmt":"2012-10-19T09:08:46","guid":{"rendered":"http:\/\/blog.ehscsi.com\/?p=602"},"modified":"2019-10-11T18:23:32","modified_gmt":"2019-10-11T22:23:32","slug":"preparing-for-an-unannounced-inspection","status":"publish","type":"post","link":"https:\/\/www.ehscsi.com\/blog\/2012\/10\/19\/preparing-for-an-unannounced-inspection\/","title":{"rendered":"Preparing for an Unannounced Inspection"},"content":{"rendered":"<p>While at a client site yesterday, I received a call that the Fire Department wanted to visit<a href=\"http:\/\/blog.ehscsi.com\/wp-content\/uploads\/2012\/10\/files.jpeg\" target=\"_blank\" rel=\"noopener\"><img loading=\"lazy\" decoding=\"async\" class=\"alignright size-full wp-image-603\" title=\"files\" src=\"http:\/\/blog.ehscsi.com\/wp-content\/uploads\/2012\/10\/files.jpeg\" alt=\"LEPC, EPCRA, environmental reporting, ehs consultant in south florida\" width=\"169\" height=\"297\"><\/a> the facility.&nbsp; About an hour later a representative from the local fire department was on-site.&nbsp; Believe it or not, he wanted to see the chemicals reported on the <a title=\"EPCRA Reporting\" href=\"http:\/\/blog.ehscsi.com\/2012\/10\/11\/epcra-reporting\/\" target=\"_blank\" rel=\"noopener noreferrer\">Tier II report<\/a> for the facility submitted earlier in the year\u2014as discussed last week the Tier II report is due by March 1 of every year.&nbsp; 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 <a title=\"Environmentally Hazardous Substances\" href=\"http:\/\/www.ecfr.gov\/cgi-bin\/text-idx?c=ecfr&amp;SID=d2341821612ad790d92b24a4af3ff7bd&amp;rgn=div9&amp;view=text&amp;node=40:29.0.1.1.11.4.17.3.14&amp;idno=40\" target=\"_blank\" rel=\"noopener noreferrer\">Environmentally Hazardous Substances (EHS)<\/a>\u2014I also conduct this evaluation for any required regulatory reports. &nbsp;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.<\/p>\n<p>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.&nbsp; Initially I was unable to find my files\u2014needless to say this caused a bit of a panic\u2014however, shortly after the inspector arrived I found the file and was able to provide him with the requested information and to correct some inaccuracies.&nbsp;&nbsp; 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\u2019s emergency response plan and a list of emergency contacts. &nbsp;This inspection points to the need to be prepared with documentation required by regulations applicable to your facility. &nbsp;It also highlights the need to ensure communications about the location of such documentation. &nbsp;What happens when the consultant or EHS professional is not on-site? &nbsp;These scenarios should also be considered and plans created to address them. &nbsp;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.<\/p>\n<p>Are you prepared for your next unannounced inspection? &nbsp;Do you have a practice that works in maintaining good records?&nbsp; Please share by leaving a comment.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>While at a client site yesterday, I received a call that the Fire Department wanted to visit the facility.&nbsp; About an hour later a representative from the local fire department was on-site.&nbsp; Believe it or not, he wanted to see the chemicals reported on the Tier II report for the facility submitted earlier in the&#8230;<\/p>\n","protected":false},"author":3,"featured_media":603,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"content-type":"","footnotes":""},"categories":[8],"tags":[153,63,25],"class_list":["post-602","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-ehs-compliance","tag-ehs-audits","tag-ehs-compliance-2","tag-ehs-consultant"],"_links":{"self":[{"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/posts\/602","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/comments?post=602"}],"version-history":[{"count":12,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/posts\/602\/revisions"}],"predecessor-version":[{"id":853,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/posts\/602\/revisions\/853"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/media\/603"}],"wp:attachment":[{"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/media?parent=602"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/categories?post=602"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.ehscsi.com\/blog\/wp-json\/wp\/v2\/tags?post=602"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}