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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. WAC 173-350-360(6)(b) requires routine inspections for: Operating hazards

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developing a facility inspection program

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
WASHINGTON HAS NEW REGULATIONS FOR MRW FACILITIES
  • WAC 173-350-360(6)(b) requires routine inspections for:
    • Operating hazards
    • Presence of operable safety equipment
    • Container integrity
    • General facility condition
  • Inspections required at least weekly or once each operating day whichever is more frequent
washington requires annual inspections
WASHINGTON REQUIRES ANNUAL INSPECTIONS
  • All secondary containment systems, including accessible below floor space, sumps, and tanks
  • All ventilation and flammable vapor monitoring systems
inspection recordkeeping requirements
INSPECTION RECORDKEEPING REQUIREMENTS
  • Date and time of inspection
  • Name and signature of inspector
  • Notation of observations made
  • Date and nature of needed repairs or remedial action
  • Notation of significant deviations from the plan of operation
so why are inspections important
SO, WHY ARE INSPECTIONS IMPORTANT?
  • Public Safety
  • Worker Health and Safety
  • Compliance with written regulations
  • Emergency Prevention and management
  • Opportunities for Education
making inspections effective
MAKING INSPECTIONS EFFECTIVE
  • Have a clear Plan of Operation
    • Cite the regulations
    • Be specific!
  • Make the Operations Plan say what you really do
examples of plan language
Poor Language

“Ensure that drums can be inspected”

“Use appropriate safety gear”

Good Language

“Ensure 30-inch clear aisle space on at least one side of drum”

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

EXAMPLES OF PLAN LANGUAGE
develop inspection checklists
DEVELOP INSPECTION CHECKLISTS
  • Daily checklists
  • Weekly or post-shipment checklists
  • Annual checklists
daily checklist
DAILY CHECKLIST

Aisle space

Container markings

Containers closed

Container integrity

Buildings clean and closed at end of day

Unknowns identified or properly contained

All wastes processed

Safety equipment operable and accessible

weekly checklist
Empty containers inventoried and ordered

Buildings cleaned and closed

Safety equipment inventoried and supplies ordered

Safety shower and eye wash tested

Spill kits inventoried and supplies ordered

Flammable gas monitoring equipment tested and calibrated

WEEKLY CHECKLIST
post shipment checklist
Secondary containment areas cleaned and free of debris and liquids

Manifests filed by end of working day

Needed maintenance identified

POST-SHIPMENT CHECKLIST
annual checklist
Secondary containment structures cleaned and tested for integrity

Ventilation and flammable vapor monitoring systems tested for operability

Buildings inspected for leaks and electrical hazards

All water lines tested for leakage

Drum moving equipment inspected

ANNUAL CHECKLIST
other annual inspection activities
Review PPE use program

Review respiratory protection program

Review training records

OTHER ANNUAL INSPECTION ACTIVITIES
make inspection checklists part of the operations plan
Signed checklists get filed each working day

Checklists should be periodically reviewed by a supervisor

Checklists must be available for the health department

MAKE INSPECTION CHECKLISTS PART OF THE OPERATIONS PLAN
finally
Inspections make everyone accountable

Inspections ensure systematic views of the facility

Inspections help prevent emergencies

FINALLY