Sooner or later, any environmental specialist faces inspections by state environmental supervision authorities, whether it be Rosprirodnadzor or a regional executive authority. The inspectors' task is to identify as many non-compliances and violations as possible, while the environmental department's task is to minimize these facts and prevent the enterprise and its officials from being held administratively liable without justification. To pass an inspection with minimal losses, it is necessary to be guided by key principles and monitor the inspectors' compliance with all procedural actions. Let's break down the main points.
Principles of Inspection Preparation and Support
The key principle for organizing inspection preparation and support is "TEAM":
Remember that openness and sufficiency of communication, along with promptly sent and received information, can significantly minimize or even eliminate potential risks. Inspection results are a team effort, which also serves as an indicator of the effectiveness of interaction between all interested structural units of the enterprise.
Taking into account that the regulatory body conducts sampling and specimen collection during almost every scheduled and unscheduled inspection, let's analyze typical inspector errors.
Typical Errors of State Environmental Supervision Authorities During Sampling
First and foremost, a representative of the state environmental supervision authority is not entitled to take samples (specimens) of products (goods), materials, or substances if they do not relate to the subject of the inspection being conducted.
In the case of sampling substances that are not production or consumption waste but are documented as waste sampling, it is necessary to state disagreement with the sampling performed and record the name of the specific substance, product, or material sampled as waste.
Based on accumulated experience, I consider it necessary to draw attention to the following typical violations of procedural actions during sampling:
1. The laboratory's scope of accreditation does not include the right to perform sampling and (or) testing of samples.
2. The order/instruction for the inspection lacks information about the experts involved in the sampling and (or) testing of the collected samples.
3. Use of equipment that has not undergone verification, certification, or calibration in the prescribed manner.
4. Use of equipment by the laboratory that is not included in its accreditation certificate.
5. Non-compliance with HSE requirements when performing work at height.
6. During the sampling process, the laboratory fails to account for natural and climatic conditions (atmospheric pressure, humidity, rain, snow, low or high ambient temperature, wind speed and direction, etc.), the observance of which is required by the sampling methodology.
7. During the sampling process, the laboratory fails to account for factors specified by the sampling methodology (flow rate, equipment operating mode, etc.) that may affect the reliability of the sample taken.
8. Conducting sampling without the participation of the person being inspected (for example, within the boundaries of the sanitary protection zone outside the territory of the inspected party).
9. Natural and climatic indicators (wind, precipitation, etc.) change during the sampling process, and these changes prevent the continuation of sampling (for example, wind direction or speed)
10. Violation of the procedure for packaging and transporting collected samples.
11. Failure to provide sampling reports/protocols, including their appendices, for review and signature by the representative of the inspected party.
All procedural violations committed must be recorded using photo and video equipment, as well as in the relevant documents (sampling report, inspection report, and others), indicating the date, time, full name, position, and power of attorney details.
Conclusion: Advance preparation for the inspection and teamwork of all structural units of the enterprise are the keys to minimizing the consequences of the state environmental supervision authority's work. Record all procedural actions of the inspectors in as much detail as possible, add comments and remarks to the reports and documents being prepared, and if a violation is still included in the Inspection Report, work through the options for appeal. Remember that inspectors are people too and can make mistakes.