How Do Those Inspectors Find Me?

There is an local EPA inspector standing in your doorway and you have no idea how your shop ended up on his/her "hit list". There are several possibilities, and the very first one that occurs to you is "one of my competitors called them up just to give me grief."

Before total paranoia sets in, consider this:

The shop's very own waste management practices could well be the reason the inspector is there. Local regulatory agencies maintain records. If a shop is registered as a painting operation and has permits on file for a spray booth, the regulatory authorities assume that painting operations are being conducted at that place of business. A shop that is painting can be producing what state inspectors define as hazardous waste. If it's being produced, it has to be removed. All the inspector has to do is compare his lists. If a shop shows up on one but not on the other, the question will be "Mr. Shop owner, what are you doing with it?"

If liquid paint waste is removed by a commercial recycler, a hazardous waste manifest will be on record and the inspector wouldn't be asking that question in the first place. Another possibility is that a shop is using a distillation system and can produce evidence that they have acquired TCLP test results on a sample of their still bottom and disposal has been negotiated with a local landfill that accepts special waste. It starts getting sticky when a shop owner doesn't have a good answer. It gets even stickier when the inspector takes a walk around the shop and finds a collection of containers full of waste thinners or waste paint. OUCH! Now, not only does the shop have the undivided attention of the inspector, the shop owner has just planted both feet in the Violation Zone.

If the collection of containers has obviously been there for awhile, the inspector may ask "Do you have a storage permit for hazardous waste?" If the container collection has been maintained outside behind the shop, the inspector will look for visible ground contamination. Discovery of possible ground contamination means the shop may have just acquired the headache of hiring a remediation firm that will have to perform soil analysis, a site scraping and confirmation samples. Additional expense can be incurred if the container integrity is questionable and the inspector requires "over packing" (placing the containers within new, larger containers to make them appropriate for transport in accordance with DOT regulation). Once over packing is complete, the containers must be removed by an authorized hauler in order for remediation to begin.

The inspector will not only want to review the shop's plans for accomplishing this, but will also want to see how a shop intends to manage their waste products in the future. The EPA fines can be enormous (in the millions) and they can be doubled if a shop owner is found to have committed a "knowing violation". Remediation expense can also carry a hefty price tag. The whole issue is a MAJOR headache.

The scenario described above has actually happened. To prevent it happening in YOUR shop, take a look at your waste management practices. Put answers in place before the questions are raised in the minds of the local inspecting authorities. Making pro-active decisions about your waste management practices will not only spare you unnecessary grief but also save you a fortune.

Copyright © Tara L. Munro. All Rights Reserved.