DEVELOPING A FACILITY INSPECTION PROGRAM Or How To Make Sure The Facility You Inspect is Operating Successfully Morson Environmental Consulting, Inc.

WASHINGTON HAS NEW REGULATIONS FOR MRW FACILITIES b WAC (6)(b) requires routine inspections for: Operating hazardsOperating hazards Presence of operable safety equipmentPresence of operable safety equipment Container integrityContainer integrity General facility conditionGeneral facility condition b Inspections required at least weekly or once each operating day whichever is more frequent

WASHINGTON REQUIRES ANNUAL INSPECTIONS b All secondary containment systems, including accessible below floor space, sumps, and tanks b All ventilation and flammable vapor monitoring systems

INSPECTION RECORDKEEPING REQUIREMENTS b Date and time of inspection b Name and signature of inspector b Notation of observations made b Date and nature of needed repairs or remedial action b Notation of significant deviations from the plan of operation

SO, WHY ARE INSPECTIONS IMPORTANT? b Public Safety b Worker Health and Safety b Compliance with written regulations b Emergency Prevention and management b Opportunities for Education

MAKING INSPECTIONS EFFECTIVE b Have a clear Plan of Operation Cite the regulationsCite the regulations Be specific!Be specific! b Make the Operations Plan say what you really do

EXAMPLES OF PLAN LANGUAGE b Poor Language b “Ensure that drums can be inspected” b “Use appropriate safety gear” b Good Language b “Ensure 30-inch clear aisle space on at least one side of drum” b “This operation requires the use of respirator, splash apron, and nitrile gloves”

DEVELOP INSPECTION CHECKLISTS b Daily checklists b Weekly or post-shipment checklists b Annual checklists

DAILY CHECKLIST b Aisle space b Container markings b Containers closed b Container integrity b Buildings clean and closed at end of day b Unknowns identified or properly contained b All wastes processed b Safety equipment operable and accessible

b Empty containers inventoried and ordered b Buildings cleaned and closed b Safety equipment inventoried and supplies ordered b Safety shower and eye wash tested b Spill kits inventoried and supplies ordered b Flammable gas monitoring equipment tested and calibrated WEEKLY CHECKLIST

b Secondary containment areas cleaned and free of debris and liquids b Manifests filed by end of working day b Needed maintenance identified POST-SHIPMENT CHECKLIST

b Secondary containment structures cleaned and tested for integrity b Ventilation and flammable vapor monitoring systems tested for operability b Buildings inspected for leaks and electrical hazards b All water lines tested for leakage b Drum moving equipment inspected ANNUAL CHECKLIST

b Review PPE use program b Review respiratory protection program b Review training records OTHER ANNUAL INSPECTION ACTIVITIES

b Signed checklists get filed each working day b Checklists should be periodically reviewed by a supervisor b Checklists must be available for the health department MAKE INSPECTION CHECKLISTS PART OF THE OPERATIONS PLAN

b Inspections make everyone accountable b Inspections ensure systematic views of the facility b Inspections help prevent emergencies FINALLY