One of the most frequently cited violations under RCRA is the lack of an internal communication system at places where hazardous wastes are being handled.
40CFR264.34 (a) states that “whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee”.
40CFR 264.32(b) goes on to state that “if there is ever just one employee on the premises while the facility is operating, he must have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance.”
The requirements are pretty clear. Yet many facilities do not have them and end up being cited by the inspector.
We have scheduled several online live webinars to discuss the most frequently cited RCRA violations and how to avoid them.
Doing the wrong thing during an agency inspection can have bad consequences. Always be prepared for any agency inspection. That means you need to have all your environmental records in good condition at all times. Make sure they are up to date and easily accessible to the inspector. The last thing you want to have happened is to have the inspector wait around at your facility while you scurry around looking for records that the inspector wants to review.
Another thing to remember is NEVER reprimand your own employees in front of any inspector. Why? It gives the inspector a very negative perception of how you run your business and treat your employees. Furthermore, you have just humiliated your employee in front the inspector and you have just made an enemy out of that employee.
There are many more tips on how to manage an inspection that are discussed at our 2-day environmental seminars. We also have a live webinar on “How to manage an agency inspection.”