Inspection Survival Course for Metal Finishers

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Overview of the course
Preparing for inspections
What to expect
What do you want the inspector to see?
On the day
The day after

Overview of the course

Introduction

 1. Introduction to the course -- what, why, and how

 2. Course Outline

 3. Additional Course Resources (left margin buttons)

 4. About the Course -- who produced it, where did the information come from?

Preparing for inspections

Developing a compliance plan

 1. Compliance Plan:  People, Paper, Preparation, and Public Relations

People

 2. Compliance Manager and Personnel Assignments

 3. Preparing your employees for an inspection

Paper

 4. Compliance Notebooks: Purpose

 5. Compliance Notebooks: How Many?

 6. Hazardous Waste Notebook

 7. Wastewater Notebook

 8. Air Notebook

 9. TRI Notebook

10. Health and Safety Notebook

Preparation

11. Compliance Checkups

12. Self Audits

13. Compliance Checklists

14. 10 Most Common Environmental Violations

15. 2 Future Metal Finishing Regulatory Problems

16. 10 Most Common Safety Violations

17. Getting Outside Help for Compliance Checkups

18. OSHA Consultation Service

19. OSHA Consultation Program:  Getting Started

20. OSHA Consultation Program:  SHARP

What to expect

Public Relations

21. Know Your Inspector

22. Various Environmental Agencies Perform Inspections

23. List of States with Approved OSHA plans

24. Agencies, Inspectors:  Similarities and Differences

25. Which agencies inspect metal finishers?  How often? (actual statistics)

26. Outcomes of Inspections:  How common are fines? (actual statistics)

27. Interacting with Inspectors

28. Compliance Plan Review

What do you want the inspector to see?

Image Enhancement

 1. Who gets inspected, and why?

 2. A good image can make your job easier -- some real-life examples

 3. Suggestions for Image Enhancement

 4. What is SGP?

 5. Why SGP?

 6. SGP Reports -- compare with other companies -- potential cost savings

 7. SGP--Getting Started

 8. Environmental Management Systems (EMS) -- what, why, and how?

 9. Components of an EMS

10. Types of EMSs

11. Question -- Why spend money on an EMS?

12. Top five reasons why companies develop an EMS

13. Question -- Why is enhanced image so high on the list?

14. One thing you can count on with an EMS

15. Costs and Benefits of a Certified EMS

16. Costs and Benefits of Non-Certified EMS

17. Question -- How does EPA feel about Certified vs. Non-certified EMS?

18. EPA Policy Statement

19. Getting Started with an EMS

20. EMS Alternatives

21. "Start-EMS" -- available free to course subscribers

22. Does "Start-EMS" Really Work?

23. Other Image Enhancement Programs

24. Consultation and Audit Programs

25. Award Programs (Attaboys)

26. Educational Programs

27. What will the inspector look for?

28. What can happen to your facility without your noticing

29. Good and Bad Images

On the day

Inspection Day

 1. Here Comes the Inspector

 2. You've been working hard on your Compliance Plan and Image Enhancement

 3. Inspection Day Agenda

 4. Why are first impressions so important?

 5. What factors create first impressions?

 6. What will the inspector see at your facility?

 7. Receptionists

 8. Your Waiting Room

 9. The Compliance Manager's Greeting

10. Inspection Day Agenda -- review

11. Hold an Opening Conference

12. How to handle the walkthrough

13. Fixing problems immediately (when you can)

14. Reviewing your records

15. Taking Split Samples

16. The Closing Conference

17. Congratulations! 

The day after

Post Inspection

 1. The Post Inspection Phase

 2. Post Inspection Activities

 3. Preparing a Written Report

 4. Revising Your Compliance Plan (If necessary)

 5. Fixing Problems Quickly

 6. Follow-Up Letter

 7. Respond to Notice of Violations (Don't Delay!)

 8. Thank you for taking the course -- get your $20 rebate

Bonus Section

Self-Audit Statutes

 1. Fed & State Policies and Laws for Self-Disclosure

 2. EPA's Small Business Compliance Policy

 3. EPA's Small Business Compliance Policy Conditions

 4. Audit Policy in Use

 5. How to Disclose Violations

 6. State Policies & Statutes

 7. List of States with Self-Disclosure Policies

 8. List of States with Privilege/Immunity Laws

 9. EPA vs. State Statutory & Regulatory Audit Privilege & Immunity Laws

10. Dealing with Discovered Violations

11. OSHA's Self-Audit Policy