Depending on your area you may get anywhere from five days up to six weeks notice for a scheduled inspection from the EPA. You aren’t going to create a compliant, living PSM/RMP program in that time frame but there are many things you can do to prepare the program you already have. Assuming you have a level 3 program in conjunction with a PSM program, here are three things you absolutely should do if you get notice of an inspection:
1) Know your material.
- The RMP Level 3 checklist that most EPA inspectors use is freely available online. Go through it and make sure you have these items covered in writing and that you know where to find them quickly.
- Check your documentation for accuracy: Every document you use to answer the questions in the RMP Level 3 checklist should be checked for accuracy. Are you doing the things the documents require in the way you say they will be done?
- Check for open recommendations. Whether they’ve been generated through Employee Participation, Incident Investigations, Process Hazard Analysis, Compliance Audits or any other source, make 100% sure that you have addressed every one of these recommendations. You don’t need to have every one of them closed, but you need a plan of action and a schedule for those actions in writing.
2) Prepare the staff – including yourself.
- Make sure everyone is aware that an inspection is going to happen.
- You don’t want to be tripping over contractors so you may wish to schedule their work at times that don’t coincide with your inspection.
- Remind your staff to “GO TO THE DOCUMENTS” in response to any PSM/RMP question.
Q: “How do you drain this oil pot?”
A: “With this written procedure.”
Q: “How much ammonia is in the system?”
A: “This inventory calculation sheet has the information you are asking for.”
- Handle this as a professional learning opportunity and you’ll do much better. Rather than having a surly demeanor and saying “What do you want?” to an inspector, why not something more like “We put a lot of effort into our PSM/RMP program to protect our employees and the environment. We’re really looking forward to this opportunity to show you all the hard work we’ve been doing and perhaps find some ways we can further improve it in light of your experience.” Now you’ve complimented the inspector and expressed your company’s desire to meet the goals of the program – nobody loses there.
- Relax: Remember they are auditing a program – not the people who implement it. It’s important that you take the inspection seriously but it’s not the inquisition. Don’t relax too much: I know of several inspections that went downhill rapidly because the staff were treating the inspection as a joke.
- Put yourself in their shoes for a second. Inspectors are generally good people trying to do a good thing – treat them as professionals. There are appropriate venues to vent your feelings on the federal or state government – the inspection is not one of them. Inspectors are used to being treated awfully so why not be the exception and treat them as a welcome guest?
- On the flip side – STAND YOUR GROUND. Support your program and your compliance efforts with RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) so the inspector is left to argue with the CCPS or the IIAR rather than you personally. Often inspectors will want to see something a certain way. When you are having an issue meeting their demands, ask them exactly what portion of the law they are referring to. PSM/RMP is a performance oriented standard – they picked the destination but your company gets to pick the path you take to that destination.
3) Prepare the facility
- Part of the inspection will include a site tour. This is no different than a visit from your mother in law – you will want to put your best foot forward.
- Plan out your route so the inspector gets to see everything they need to see while showing the facility in the best light.
- Do some dusting, painting, re-labeling and tagging as needed. A little bit of housekeeping goes a long way in establishing good will.
- LOOK at your system. A dented drain pan will draw questions about “struck-by hazards”, a fresh weld and unpainted pipe will draw questions about Management of Change, frost on insulation will draw questions about Corrosion Under Insulation and Non-Destructive Testing, etc. Be prepared for these questions and have ready answers.
The steps above WILL prepare you for an EPA inspection and they WILL improve your results. What they can’t do is cover up a program that has been neglected for years, but if you are reading this then that’s probably not your situation. Almost any program that has not been completely neglected can be improved and polished enough to pass most EPA inspections with the help of a great compliance consultant.
If you find yourself in need of some advice, some pre-audit assistance or a compliance audit / gap analysis, you can always call on your favorite resource for some assistance before the inspection. I would love to hear from you and help you prepare. You don’t have to be in this alone!