For anyone responsible for maintaining environmental regulatory compliance at a facility, few things can disrupt an otherwise peaceful day like an unexpected visit from a regulatory agency inspector. The best way to reduce the stress is to ensure your facility maintains an audit-ready posture at all times. While maintaining an audit-ready posture is ongoing process and not a one-time event, there are a few suggestions that will help start you down the right path.

One of the best steps you can take to stay audit-ready is to get and stay organized. Organization has a multitude of benefits, but two are of particular importance. First, organization makes it easier to ensure you have all of your bases covered. The easier it is for you to make that check, the more likely it is that you will do it on a regular basis and the more confident you will be at crunch time. This can be especially important when there are personnel changes. The second major benefit of organization is being able to quickly provide any document or record that the inspector requests. An organized and intuitive centralized filing system means that when your head of maintenance wins the lottery or retires, you do not have to worry about how he organized the shipping documentation or training records for the maintenance personnel. Not only can a lack of organization give the inspector the impression your facility does not take environmental compliance seriously, but it also can provide the inspector with some loose threads to pull on. These loose threads can lead inspectors in a direction they might not have planned on going and open up your facility to additional scrutiny and inquiry.

Something that can come up unexpected during an inspection is the interconnectedness between various environmental programs. Unfortunately, if the first time you realize this relationship is when there is an inspector on site, it may already be too late. For example, most facilities are well aware of the complexity of the regulations addressing hazardous waste. Environmental managers go to great lengths to ensure the employees responsible for hazardous waste management have the necessary tools and training to properly manage and ship hazardous waste according to the Resource Conservation and Recovery Act (RCRA).  What many facilities do not consider is if that same employee signs the shipping manifest for the hazardous waste shipment, that employee is a hazmat employee, according to the Department of Transportation (DOT) and also needs to have the required DOT training. This also goes for the employee who prepares the drums or other package for shipment or performs any other duties of a hazmat employee, as defined by the DOT.

Many facilities have gone the extra step to maintain procedures and documentation in online databases on either internal intranets or on a third party system accessible via password. Such online systems not only ensure the same procedure or process is being used by all personnel throughout the facility and no “out of date” or obsolete versions of procedures are floating around, but they also allow for scanned or electronic versions of required records to be available at the click of a mouse. If one of these electronic databases is used, however, it is important to keep in mind that for many environmental records you also must keep the original hardcopy on file to produce at the request of an inspector. While an electronic system may not mean you can do away with all paperwork and hardcopy recordkeeping, being able to quickly show inspectors an electronic copy of your current training records or most recent hazardous waste storage area inspection logs may be sufficient to convince them you are taking the necessary steps to ensure compliance. Just make sure you are ready to show the inspectors the original hardcopy of those same records if they are required to be maintained on file.

Keeping all of this in mind, a prudent starting point on your journey towards a constant audit-ready posture is to perform a comprehensive environmental audit. An environmental audit, when performed by someone not directly involved in the facility’s day-to-day operations, will help to identify which environmental regulations apply to your operations. Not only does this help to make sure you have all of the necessary permits, training, records and procedures, but it also provides an opportunity to take advantage of state or Environmental Protection Agency (EPA) audit policies and “self-disclosure” options.

There are many steps a facility needs to take in order to maintain audit-readiness, and only a few of them have been discussed above. It is important to remember that environmental compliance is an ongoing process and is not something to only think about during reporting season or annual training time. Not only does being constantly audit-ready reduce the stress of an unexpected inspection, but it also helps to engrain environmental compliance into the culture of the facility operations making compliance business-as-usual.