There are a couple of things to keep in mind about your environmental plans.
The first thing to remember is that many plans are “performance based”. It means that it is not sufficient to say what you are going to do in a plan, you must actually do it! The SPCC (spill prevention control and countermeasures) plan is a classic example. If you – or the consultants who prepared your plan – say you are going to do weekly inspection of your oil storage area, you are expected to have a weekly inspection checklist to show the EPA inspector. The agency will always look for “evidence of implementation” on your part. So if you can’t do it, don’t put it down in your plan. The same goes for RCRA contingency plans, and storm water pollution prevention plan.
The second thing to remember is that you must sign and date your plans and keep them current. Many facilities have been cited for not having their SPCC plan signed off by their plant management. They also get a citation if the lists of personnel in the plans are not current.
The third thing to remember is to keep your training records up to date. Regulatory agencies have this saying: “If there is no training record, the training never happened.”
These are the most commonly cited violations because they are easy for the inspector to uncover.