Ask an Expert: How to prepare for an audit

In this month’s feature, BC’s Paul Pepler talks about how to prepare your facility for an audit.

Question: With increasing penalties associated with Emergency Planning and Community Right-to-Know Act (EPCRA) violations, evolving requirements, and Tier II reports due March 1, how can we help make our facility audit-ready?

Answer: Filing an EPCRA report on time is just part of compliance. Facilities need to maintain backup documentation and records to demonstrate how they reported in the event of an audit. As you prepare your facility, here are some things to keep in mind:

Preparation

Each Year, reread the rule — it’s short. Read instructions and guidance documents available from the EPA or local agencies.

Physical inventory

Walk your facility and identify and document tanks, totes, bins, dry storage, and in-process storage.

Applicability evaluation

• Quantify maximum on-site storage amounts using container capacity, number of containers, density, and Safety Data Sheet (SDS) information. Technical data sheets and environmental data sheets can be helpful as well, if available.
• Review purchasing records to identify any material that is stored but was not identified during the physical inventory.
• Identify Extremely Hazardous Substances (EHS) contained in materials based on the Consolidated List of Lists or 40 CFR 355 Appendix A and B (any identified EHS must be summed facility-wide).
• Compare estimated maximum storage quantities of hazardous and extremely hazardous chemicals to the applicable thresholds. Note: Documentation for not reporting is just as important as documentation for reporting.
• Identify any exemptions that may apply. If you elect to utilize exemptions, document exactly how you meet the specific exemption criteria so that anyone reading the justification has enough information to make a determination.

Prepare Tier 2 reports

• Use the information prepared for the applicability evaluation to prepare reports.
• Save a copy of each SDS used in the applicability evaluation with this reporting year’s file. Formulations change, and, if you are audited, you will want to easily identify the SDS that was representative of the product during the reporting year and used to prepare the Tier 2 report.

Quality control

• Perform your own quality check of all information and calculations including consistency between Tier 2 report, supporting documentation, calculations, and SDS.
• Have someone else review the information for completeness, accuracy, clarity, and consistency.

Submittal

• Each year, confirm the submittal methods required by the SERC, local emergency planning committees (LEPC), and local Fire Department. If submitting via email, confirm file format and email addresses prior to the submittal date. These do change.
• Document your submittal by saving copies of emails or confirmation received.