Monthly Archives: April 2008

A few pointers on how to manage an agency inspection

Let’s look at  a few pointers on how to manage an agency inspection.


If you know you are going to be inspected, you need to do you own mock inspection to make sure everything is fine. Fix any problem before the inspector shows up. 


There is absolutely no need nor is it desirable for you to write down all your violations. You should focus your energy on fixing the problems.   


Be sure that you have read and understood all your permits and what they require you to do. For example, if your air permit requires you to keep track of the amount of each coating used during each day, you should do so.


Make full use of agency’s inspection checklists that are available on many agencies’ websites. The checklists show you what the inspection will be looking for. Use these lists in your mock audit.


Take the time to look at agencies’ inspection manuals. EPA has a manual on how to conduct a multi-media inspection. There is also one on conducting hazardous wastes inspection.  These are the same documents that the agencies use to train their own inspectors. They will provide you with a lot of insights.


You can download these from Norman’s website


Always try to resolve issues at the lowest possible level! Why?,  because The higher the level you go, the less control you will have of the process. The last thing you want is to have a judge who has no idea how you make your products telling you how you should make your products.


This is one of the many topics we cover in our popular 2-day environmental seminars.




The basic elements of an emergency response plan

Every business that stores hazardous wastes on site are required to have an emergency response plan. If you are a small quantity generator – one that generates less than 2200 lbs (approximately five 55-gallon containers) each calendar month – you do not need to have a WRITTEN plan. But you still have to have a plan.

An emergency response plan provides answers to the following questions: 

  1. Who is in charge?
  2. Who are you going to call?
  3. Where can you find the emergecny response equipment?
  4. Do you know how to use the equipment?

Here is a short video clip from the California Department of Toxic Substances Control (DTSC) on this topic. Very instructive and straight forward. Enjoy the video.


How to determine reactivity of hazardous waste

One of the four characteristics of a hazarodus waste is “reactivity”. The other three are ignitability, toxicity and corrosivity and these three characteristics are pretty easy to define by measuring the flash point, concentration and pH respectively. Reactivity is a bit harder (less objective) to determine.

The California Department of Toxic Substances Control (DTSC) has a short video clip on how to determine reactivity. In general, if something is going to go “boom”, it is likely to be reactive. Or if the MSDS states that a material is reactive with water or unstable, the waste that is derived from that material is likely to be a reactive waste. Enjoy the video.