This entry discusses what to expect during an EPA audit, what records you will be required to produce, and how the right software can ease the process.

Picture an EPA surprise audit. Then imagine two scenarios.

In one, a red-faced COO tries frantically to answer the inspectors’ myriad of questions. He is frenetically shuffling through piles of papers, stacks of dogeared index cards, and extant Post it® Notes. He has a #2 pencil clenched prosaically between his teeth. He is perspiring. The inspectors believe that his disorganization is an analog for his hazardous waste management practices. This will not end well.

In another, said COO nonchalantly answers inspectors’ questions, mouse in hand, as he clicks smoothly through a software program that has organized, categorized, and otherwise arranged the pertinent data for him. At his fingertips are summaries of all data crucial for the audit. The inspectors cannot help but infer that his hazardous waste management practices are as organized as his recordkeeping. This predicts a happier ending.

So how does the right software help you avoid the first scenario and instead achieve the second? First, let’s review what to expect during an EPA audit and what records you will be required to produce on demand. Q&As include:

1. How does an EPA audit generally proceed?
2. What paperwork is required as part of an EPA audit?
3. What paperwork requirements are common to an EPA audit?
4. How can you make sure an EPA audit goes as smoothly as possible?
5. How can the right software help make you “audit ready?”
6. What is The PegEx Platform?

1. How does an EPA audit generally proceed?

An EPA audit typically begins with an opening conference. It will involve all personnel that has a hand in your hazardous waste management. Checklists and any other information the EPA inspectors might request in advance will be reviewed. Your files will be inspected. They will be critiqued. And a walking tour of your facility will likely ensue. Finally, there will be the “closing conference” where your destiny will be discussed.

2. What paperwork is required as part of an EPA audit?

The form-filling requirements across different kinds of enterprises that generate hazardous waste are fairly similar. But there might be paperwork mandates that are specific to your particular kind of business or industry. 

Your documentation needs to be organized and kept together in the same place. In the old days, that would be in a designated filing cabinet drawer. But these are not the old days, and shuffling through file tabs to answer inspectors’ questions is not going to endear you to them. You need appropriate software to manage digital documents.

3. What paperwork requirements are common to an EPA audit?

As mentioned in Q.2, different types of enterprises must maintain documentation specific to the kinds of hazardous waste they generate and how they do so. That said, the following eight items are commonly required of all hazardous waste generators.

• Contingency plan for hazardous waste management. This paperwork is required of all TSDFs. It is also required for LQGs. Your plans need to be clearly explained. Individual employees must know their respective duties in the event of an emergency, and their contact information must be current.
• Hazardous waste training records for personnel. Individual LQG personnel must complete annual training. And you must have training records extant for each at least three years after his or her leaving your employ.
• Records of waste determination. You must have records about how you identified something as hazmat and what danger it presents. Just as importantly, you should be able to show how you identified something as a non-hazardous waste in case you are challenged about it. These records must be available for at least three years after the last treatment, storage, or disposal of material.
• Generator’s biennial report. This must be available for three years after the due date, which is generally March 4th of even-numbered years.
• Hazardous waste manifests. These are a key part of most hazardous waste inspections. As a hazmat generator, you are required to keep a copy of the manifest signed by the transporter. After the waste is accepted by the transporter, you must have a confirmation copy of the manifest with the TSDF’s signature. Both must be retrievable for three years. These requirements are most easily met by using the E-manifest system. (You can learn more about the soon-to-be-mandatory E-manifest system here.)
• Land disposal restriction documentation. Particular notification and determination records must be kept onsite for three years after you ship a hazardous waste offsite for treatment before disposal.
• Tank and storage area inspection records. If you have hazardous waste that is managed in tanks, those tanks must be inspected daily. You must keep records of those inspections on file until the facility closes, along with an engineering assessment of the integrity of your tanking system.
• Incident reports. If you experience an incident that involves your contingency plan (see A), you must maintain records of the time, date, and details of what happened until your facility closes.

4. How can you make sure an EPA audit goes as smoothly as possible?

In a word—practice! Conduct mock audits wherein your personnel practice pulling samples, retrieving records, and answering pointed questions from hostile inspectors. Such a facility with Q&As under pressure will not only increase the chances that your audit goes smoothly. It can reasonably inspire the inspectors to limit the scope of their investigation: “Nothing to see here. Let’s move along.”

5. How can the right software help make you “audit ready?”

The best way to be “audit ready” is to have systems in place that can accurately track the generation, storage, transportation, and eventual disposal of your hazardous waste—and well before the specter of an EPA audit rears its head.

It is becoming less and less tenable to do this without software. Some organizations have multiple FTEs spending weeks and months of precious time and resources girding for audits with paper and pencil. It is not a sustainable strategy. (Just ask your CFO.)

The dynamic volume of information demanded by the EPA, DOT, OSHA, and other environmental authorities demands a software solution. You need a platform that can populate various government forms with numbers, codes, and other data demanded by state, federal, and local agencies—and do so consistently and accurately.

6. What is The PegEx Platform?

The PegEx Platform is an easy-to-use cloud-based software solution that empowers your business or enterprise to enhance compliance, enable sustainability, reduce risk, and improve workforce efficiency and accountability.

It offers a significant advantage over off-the-shelf software in that it requires no customization to accommodate hazardous waste transporter, storage, or treatment enterprises: a result of being designed and built by people who are experts in the business of hazardous waste management themselves—not software generalists.

Whether you need information at your fingertips to deal with a surprise audit, or you want to save time completing your Biennial report, PegEx’s automated workflows and audit functionality will save you time, improve accuracy, and minimize audit headaches.

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