All hazardous waste generators in Hennepin County are inspected. Inspections are conducted to help ensure that your business is properly managing its hazardous waste and provide an opportunity for you to learn more about managing hazardous waste.
The following are answers to some frequently asked questions that will help you know what to expect the next time an inspector visits your facility.
Why am I being inspected?
- Inspections can be conducted for several reasons. The inspection could be routine, could be the result of a recent complaint filed with the county, or could be a follow up from a prior inspection. Inspections are conducted to evaluate your business’ compliance with the Hazardous Waste Rules.
- Inspectors have the legal authority to enter your facility and conduct an inspection under the Hennepin County Hazardous Waste Ordinance.
Tip: Although inspections are regulatory in nature, inspectors can help you better understand the hazardous waste rules and how to manage your waste properly. Be sure to ask them any questions you have about hazardous waste management and rules.
When can I expect to be inspected?
- All inspections are done unannounced, but they will occur during regular business hours.
- Upon arrival, the inspector will introduce him/herself and provide proper identification. The inspector will ask for the site contact. If the site contact is unavailable, they will ask for someone who is familiar with your facility, wastes and processes.
- Because inspections are unannounced, the inspector understands that you may need to juggle schedules or make other arrangements to accommodate the inspection that day. Be aware that the inspector will not come back at a more convenient time just because you are unavailable.
- The frequency that your operation is inspected depends on your generator size and assigned risk. Your risk may be adjusted based on your business’s compliance with hazardous waste rules. If serious or repeat violations are observed, you may be inspected more frequently. If your business demonstrates that you are in full compliance, you will have less frequent inspections.
Tip: It’s a good idea to have several people on site that are knowledgeable with hazardous waste rules just in case you have a change in staff or you are unavailable when the inspector shows up at your facility.
How will the inspection begin?
- The inspector will ask you to describe what your company does and the types of operations and processes that you have at your site. The inspector will also review the wastes generated and amounts reported on your annual relicensing application.
Tip: Knowing how wastes are generated at your site will help the inspector understand your facility operation better, ensuring a smoother inspection.
What areas of my facility will the inspector want to see?
- The inspector will want to visit all areas where waste is generated, handled, processed, treated and stored, as well as your emergency equipment storage areas.
- During the walk-through, the inspector may ask other personnel questions about the processes or wastes generated in their work areas.
- The inspector will take notes and will sometimes take pictures and samples.
Tip: Inform the inspector of your site safety procedures and ask questions at any time during the inspection for clarification.
What types of records will the inspector ask to review?
The inspector will want to review:
- Receipts, shipping papers/logs, and waste manifests for hazardous and non-hazardous wastes that have been shipped in past three years.
- Industrial discharge permits and analytical reports (if applicable).
- The past three years of weekly container inspection logs (if applicable).
- Self-monitoring records and operation records (if applicable).
The inspector may review and photocopy material safety data sheets of chemicals used and any laboratory analyses done on wastes to determine which wastes are hazardous or non-hazardous and how to properly manage them.
Large quantity generators will need to provide additional records, such as yearly personnel training documentation and a contingency plan.
Tip: Keeping records well-organized and accessible will help keep the inspection time to a minimum and enhance your ability to comply with record-keeping requirements.
What happens after the inspection?
- The inspector will review observations made, go over any violations noted, request clarification if necessary, and inform you if more information is needed. The inspector will provide you with any information that is needed for your company to manage your waste properly.
- Corrective actions that need to be completed will either be left with the contact at the inspection or a letter will be sent to the company at a later date with a deadline for corrective actions to be completed.
- The generator usually needs to submit a written response that describes how each violation observed during the inspection was corrected.
- Unresolved issues can lead to a re-inspection of the facility or enforcement, including citations with a payable fine or citations requiring a mandatory court appearance.
Tip: Consider setting up a self-assessment program at your facility that could be conducted on a regular basis. This would help you stay in compliance with hazardous waste rules by regularly walking through your facility and noting any issues that may need further attention.
Remember that although inspections are regulatory in nature, they are also designed to be educational. Cooperating with the inspector and correcting any concerns is the key to a successful inspection.