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285_InspectingtheInspection_AllSpeakers
RETAIL SUSTAINABILITY CONFERENCE 2015 BE A CATALYST FOR CHANGE Title Sponsor Title Sponsor A Drama in Three Acts Title Sponsor AMY EBERSOLE-MARTINEZ (NEW EMPLOYEE) Senior Safety & Environmental Analyst Petco Animal Supplies, Inc. ANDREW J. MARKS (INSPECTOR) Senior Counsel Regulatory Law, Walgreen Co. CHRIS HALEY (EHS MANAGER) Director, Legal Technology, Troutman Sanders Emerge WADE SCHEEL (SUPERVISOR) Director, Environmental Safety & Health Stericycle Environmental Solutions Title Sponsor ACT I Title Sponsor INTERMISSION I Title Sponsor INTERMISSION I Real-World Examples and Implications We had an inspection and… – Missing paperwork caused a citation • This led the inspector to inspect ALL the stores in his area – Had unsegregated waste items. • This could cause reactions among the chemicals that are being commingled (i.e. acids with bases; flammables with reactives) Title Sponsor INTERMISSION I Best Management Practices If we had only… – Made sure the HazWaste binder was easy to locate and up-to-date – Properly trained new employees in onboarding • This would have eliminated commingling waste – Given new employees “customer service” training • Would have given the employee some tools to work with when handling an inspector Title Sponsor INTERMISSION I The Numbers – Top Findings Finding Category Finding Description % of Total Findings Manifest Manifest(s) not onsite 22% Container Management Container is not labeled or label is not completed (e.g., no start date) 14% Other Documentation Annual/Biennial hazardous waste report was not available onsite and/or not submitted to agency 13% Weekly Inspections Failure to conduct/document weekly inspections 12% Training Training Records not available onsite 10% Contingency Plan Failure to provide Contingency Plan to emergency responders 7% Other Documentation Aid Notification Letters not available 6% Other Documentation State registration information does not match manifest(s) 5% Container Management Box should be closed except when adding waste 5% Other Documentation HMBP should be revised (CA Only) 5% Source: Client data stored in Compilot Inspection Manager application created by Troutman Sanders eMerge Title Sponsor Poll: What are the top 3 findings/citations at your locations? Title Sponsor ACT II Title Sponsor INTERMISSION II Title Sponsor INTERMISSION II Real-World Examples and Implications We had an inspection and… – The paperwork was in order • Employee was trained properly • General Manager ensured binder was organized and up to date • Aided in preventing the inspector from digging deeper – All items were segregated/labeled properly • Ensured compliance and mitigated any fire risk – New employee was more professional with inspector Title Sponsor INTERMISSION II Best Management Practices Solutions that work… – Having a Hazardous Waste binder on the HW rack • All manifests, weekly inspections and LDRs kept in same location and makes it easy to locate during inspections – Have a dedicated person for the HW area • Responsible for making sure the rack is organized and inspected Title Sponsor INTERMISSION II The Numbers – Top Findings Ratio of Inspections With & Without Findings Inspections without Findings 61% Inspections with Findings 39% Source: Client data stored in Compilot Inspection Manager application created by Troutman Sanders eMerge Title Sponsor Poll: What percentage of your inspections result in compliance findings? Title Sponsor Poll: What percentage of your inspection with findings result in enforcement? Title Sponsor ACT III Title Sponsor INTERMISSION III Title Sponsor INTERMISSION III Data Tools Pre-Inspection – Electronic documentation and controls – Reminders – Self inspections and internal compliance evaluations – Training resources Title Sponsor INTERMISSION III Data Tools Post-Inspection – Centralized inspection report management – Process management for compliance and risk reduction – Communication and response tracking – Data analysis and reporting – Actionable analytics to help improve programs Title Sponsor INTERMISSION III Data Tools – Types of Analysis & Reporting Inspections By Facility Type Findings At Facilities With Specific Features 35 30 Retail 82% 25 20 Distribution 16% 15 10 5 0 Other 2% Source: Example data for illustration - Compilot Inspection Manager application created by Troutman Sanders eMerge Title Sponsor INTERMISSION III Data Tools – Types of Analysis & Reporting 180 153 160 141 137 140 123 122 124 120 103 98 100 Findings 80 83 88 Inspections 75 60 40 51 58 59 60 51 20 0 Source: Example data for illustration - Compilot Inspection Manager application created by Troutman Sanders eMerge Title Sponsor INTERMISSION III Data Tools – Types of Analysis & Reporting Inspections By State Source: Client data stored in Compilot Inspection Manager application created by Troutman Sanders eMerge Title Sponsor Poll: Excluding California, what is the State where you are receiving the most environmental inspections? Title Sponsor Poll: Excluding California, what States are issuing NOV/Penalties/Citations as a result of inspections? Title Sponsor INTERMISSION III Best Management Practices Solutions that work over time… – Electronically filing all the paperwork • Allows easy accessibility for corporate & retention tracking – Training tracked electronically • Instant visibility to who has completed training and who is behind Title Sponsor Title Sponsor Live Content from Conferences i/o Title Sponsor
