What to Expect from a Compliance Inspection in Connecticut
What to expect
Two agencies, the Occupational Safety & Health Administration and the Department of Energy & Environmental Protection (OSHA and DEEP), conduct inspections at facilities throughout the state of Connecticut. Under state law, inspectors have the authority to enter a facility at reasonable times to evaluate compliance with permits and state regulations.
Inspections are unannounced so normal operating conditions can be observed. However, regulators may give some notice based on your company’s working relationship with the agencies.
It is the responsibility of your organization to provide thorough and complete answers to any questions asked. Furthermore, records and reports required under your permit must be available for review and inspection. At this point, it is important to keep in mind that you should only give inspectors what they have asked for. Any other material could cause confusion among all parties. So, if asked for records from 2022, give the inspector records from 2022.
How should you prepare for an inspection?
Identify other employees who are familiar with the site, operations, and the location of pertinent records like operator logs, inspection logs, and training records. Name an alternate contact who would, at a minimum, be available to escort inspectors through the facility when the primary contact is not available. Remember always to escort any inspectors throughout the site. A facility could be dangerous to visitors that do not know what hazards are present, including those from regulatory agencies.
The inspector may return for a more detailed inspection when the main contact is present or may conduct the full inspection on the initial visit if appropriate and if the objectives of the inspection can be achieved.
The inspector is there to determine if the facility and its systems are properly operated, properly maintained, and conform to approved plans and specifications. The inspector will also look for proper record-keeping.
What will the inspector do?
The inspector will interview personnel, inspect plant components, tour the facility, and review the operation and records. Inspectors may also collect samples as appropriate, i.e., wastewater samples, if inspecting a wastewater treatment facility. Associated plans, if pertinent to the type of inspection being performed, may be requested by the inspector.
What happens after the inspection?
The inspector will summarize the findings, often in a closing meeting, and attempt to identify readily apparent issues or concerns seen during the inspection and site walk. The inspector may need to confer with additional staff based on their notes and documentation obtained while inspecting the site.
Any non-compliance issues should be corrected as soon as possible. Corrective actions to the identified issues must be documented.
If appropriate, the agency may issue a “Notice of Violation” (NOV). The NOV is to ensure that the non-compliant findings will be adequately corrected. It is important to address these violations. Ignoring them may result in fines.
Walden can assist before, during, and after inspections from a regulatory agency. Visit our EHS advisory services page to learn how our EHS team can help your organization maintain compliance with all applicable regulations. If you have any questions on how to prepare for and handle compliance inspections, please contact us at 516-758-1273.