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

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DEVELOPING A FACILITY INSPECTION PROGRAM

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  1. DEVELOPING A FACILITY INSPECTION PROGRAM Or How To Make Sure The Facility You Inspect is Operating Successfully Morson Environmental Consulting, Inc.

  2. 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

  3. WASHINGTON REQUIRES ANNUAL INSPECTIONS • All secondary containment systems, including accessible below floor space, sumps, and tanks • All ventilation and flammable vapor monitoring systems

  4. 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

  5. SO, WHY ARE INSPECTIONS IMPORTANT? • Public Safety • Worker Health and Safety • Compliance with written regulations • Emergency Prevention and management • Opportunities for Education

  6. MAKING INSPECTIONS EFFECTIVE • Have a clear Plan of Operation • Cite the regulations • Be specific! • Make the Operations Plan say what you really do

  7. 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

  8. DEVELOP INSPECTION CHECKLISTS • Daily checklists • Weekly or post-shipment checklists • Annual checklists

  9. 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

  10. 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

  11. Secondary containment areas cleaned and free of debris and liquids Manifests filed by end of working day Needed maintenance identified POST-SHIPMENT CHECKLIST

  12. 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

  13. Review PPE use program Review respiratory protection program Review training records OTHER ANNUAL INSPECTION ACTIVITIES

  14. 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

  15. Inspections make everyone accountable Inspections ensure systematic views of the facility Inspections help prevent emergencies FINALLY

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