Is your facility well-prepared for an unannounced inspection?
All companies and laboratories that deal with hazardous waste need to take the appropriate steps to prepare for planned inspections. However, there will be times when agents show up to your facility unannounced to make an inspection. Advance preparation is the key to ensuring that these surprise visits don’t end with violations and excessive fines. Here is a general guideline to cross-check against your current preparations to see if your company or laboratory is ready for an unannounced inspection.
Up-to-Date Emergency Contact Information
One of the first things an inspector checks upon arriving at your facility is your emergency contact information. It’s important to make sure that this information is up-to-date and accurate at all times. In addition, it is critically important to check the primary and secondary methods of acquiring an SDS in case of emergency. For example, if your primary method of obtaining an SDS is through the internet, make sure you’re also familiar with an extra method, such as calling an emergency hotline, and that your facility has the capability to receive an SDS fax.
Checking Up on Your Main Accumulation Area
Your main accumulation area (MAA) reflects your overall hazardous waste management program. Deficiencies in this area are likely to lead to higher scrutiny during the rest of your unannounced inspection. Make sure that this area is completely in compliance and as clean and orderly as possible. Have your emergency contact info posted conspicuously and that there is a phone nearby. And check to make sure that your MAA inspection logs are filled out completely, taking all long weekends and holiday schedules into account. Weekly logs are supposed to be kept on file for three years.
Basic Lab Maintenance
Once inside your facility, the inspector will interview your staff on areas such as waste management, proper safety procedures, and any chemical compatibility issues in your storage areas. Make sure your lab is properly maintained and that all out-of-date or unusable chemicals are not stored in it. Your staff should be properly trained on chemical storage and labeling techniques. And make sure all lab training records and SOPs are up-to-date and available.
For help with preparing your facility for an unannounced inspection, contact AEG Environmental today.
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