DEVELOPING A FACILITY DEVELOPING A FACILITY INSPECTION PROGRAMINSPECTION PROGRAM

Or How To Make Sure The Or How To Make Sure The Facility You Inspect is Operating Facility You Inspect is Operating

SuccessfullySuccessfully

Morson Environmental Morson Environmental Consulting, Inc.Consulting, Inc.

WASHINGTON HAS NEW WASHINGTON HAS NEW REGULATIONS FOR MRW REGULATIONS FOR MRW FACILITIESFACILITIES

WAC 173-350-360(6)(b) requires WAC 173-350-360(6)(b) requires routine inspections for:routine inspections for:• Operating hazardsOperating hazards• Presence of operable safety equipmentPresence of operable safety equipment• Container integrityContainer integrity• General facility conditionGeneral facility condition

Inspections required at least weekly or Inspections required at least weekly or once each operating day whichever is once each operating day whichever is more frequentmore frequent

WASHINGTON REQUIRES WASHINGTON REQUIRES ANNUAL INSPECTIONSANNUAL INSPECTIONS

All secondary containment All secondary containment systems, including accessible systems, including accessible below floor space, sumps, and below floor space, sumps, and tanks tanks

All ventilation and flammable All ventilation and flammable vapor monitoring systemsvapor monitoring systems

INSPECTION INSPECTION RECORDKEEPING RECORDKEEPING REQUIREMENTSREQUIREMENTS

Date and time of inspectionDate and time of inspection Name and signature of inspectorName and signature of inspector Notation of observations madeNotation of observations made Date and nature of needed repairs Date and nature of needed repairs

or remedial actionor remedial action Notation of significant deviations Notation of significant deviations

from the plan of operationfrom the plan of operation

SO, WHY ARE SO, WHY ARE INSPECTIONS IMPORTANT?INSPECTIONS IMPORTANT?

Public SafetyPublic Safety Worker Health and SafetyWorker Health and Safety Compliance with written regulationsCompliance with written regulations Emergency Prevention and Emergency Prevention and

managementmanagement Opportunities for EducationOpportunities for Education

MAKING INSPECTIONS MAKING INSPECTIONS EFFECTIVEEFFECTIVE

Have a clear Plan of Have a clear Plan of OperationOperation• Cite the regulationsCite the regulations• Be specific!Be specific!

Make the Operations Make the Operations Plan say what you Plan say what you really doreally do

EXAMPLES OF PLAN EXAMPLES OF PLAN LANGUAGELANGUAGE

Poor LanguagePoor Language ““Ensure that Ensure that

drums can be drums can be inspected”inspected”

““Use appropriate Use appropriate safety gear”safety gear”

Good LanguageGood Language ““Ensure 30-inch Ensure 30-inch

clear aisle space on clear aisle space on at least one side of at least one side of drum”drum”

““This operation This operation requires the use of requires the use of respirator, splash respirator, splash apron, and nitrile apron, and nitrile gloves”gloves”

DEVELOP INSPECTION DEVELOP INSPECTION CHECKLISTSCHECKLISTS

Daily checklistsDaily checklists Weekly or post-shipment checklistsWeekly or post-shipment checklists Annual checklistsAnnual checklists

DAILY CHECKLISTDAILY CHECKLIST

Aisle spaceAisle space Container markingsContainer markings Containers closed Containers closed Container integrityContainer integrity Buildings clean and closed at end of dayBuildings clean and closed at end of day Unknowns identified or properly containedUnknowns identified or properly contained All wastes processedAll wastes processed Safety equipment operable and accessibleSafety equipment operable and accessible

Empty containers inventoried and orderedEmpty containers inventoried and ordered Buildings cleaned and closedBuildings cleaned and closed Safety equipment inventoried and supplies Safety equipment inventoried and supplies

orderedordered Safety shower and eye wash testedSafety shower and eye wash tested Spill kits inventoried and supplies orderedSpill kits inventoried and supplies ordered Flammable gas monitoring equipment Flammable gas monitoring equipment

tested and calibratedtested and calibrated

WEEKLY CHECKLISTWEEKLY CHECKLIST

Secondary containment areas Secondary containment areas cleaned and free of debris and cleaned and free of debris and liquidsliquids

Manifests filed by end of working Manifests filed by end of working dayday

Needed maintenance identified Needed maintenance identified

POST-SHIPMENT POST-SHIPMENT CHECKLISTCHECKLIST

Secondary containment structures Secondary containment structures cleaned and tested for integritycleaned and tested for integrity

Ventilation and flammable vapor Ventilation and flammable vapor monitoring systems tested for monitoring systems tested for operabilityoperability

Buildings inspected for leaks and Buildings inspected for leaks and electrical hazardselectrical hazards

All water lines tested for leakageAll water lines tested for leakage Drum moving equipment inspectedDrum moving equipment inspected

ANNUAL CHECKLISTANNUAL CHECKLIST

Review PPE use programReview PPE use program Review respiratory protection Review respiratory protection

programprogram Review training recordsReview training records

OTHER ANNUAL OTHER ANNUAL INSPECTION ACTIVITIESINSPECTION ACTIVITIES

Signed checklists get filed each Signed checklists get filed each working dayworking day

Checklists should be periodically Checklists should be periodically reviewed by a supervisorreviewed by a supervisor

Checklists must be available for Checklists must be available for the health departmentthe health department

MAKE INSPECTION MAKE INSPECTION CHECKLISTS PART OF THE CHECKLISTS PART OF THE OPERATIONS PLANOPERATIONS PLAN

Inspections make everyone Inspections make everyone accountableaccountable

Inspections ensure systematic Inspections ensure systematic views of the facilityviews of the facility

Inspections help prevent Inspections help prevent emergencies emergencies

FINALLYFINALLY