IPS Environmental Audit

Information

Document No.
Audit Title
Client / Site
Conducted on
Prepared by
Location
Personnel

General Housekeeping Conditions

Is Housekeeping done on a regular basis?
Corrective Action(s):
Is someone designated to ensure housekeeping is properly maintained?
Corrective Action(s):
Are there old oil, fluid, material spills that have not been addressed?
Corrective Action(s):
Are there spills covered in absorbent that have not been cleaned?
Corrective Action(s):
Are tools, rags, and other maintenance items returned to their proper storage place once maintenance is complete?
Corrective Action(s):
Are there tools, chemicals, equipment that can be removed or sold?
Corrective Action(s):
Is the facility large enough for the equipment, tools, and chemicals stored?
Corrective Action(s):

SPCC Plan

Add up the volume of oil containers greater than 55 gallons. Is that number greater than or equal to 1320 gallons? If yes, an SPCC plan is required.
Corrective Action(s):
If the total amount is within 200 gallons of 1320, does the facility have to have all of the oil storage containers?
Corrective Action(s):
Is the SPCC plan certified by a PE?
Corrective Action(s):
Is the SPCC Plan approved by the current district manager and district HSE representative?
Corrective Action(s):
Are the address and company name accurate?
Corrective Action(s):
Does the list of required secondary containment and facility layout reflect the current state of the facility?
Corrective Action(s):
Is the Spill Emergency Contact list current and verified?
Corrective Action(s):
Are changes to management, spill team, emergency contacts, oil storage, or the facility reflected in the plan within 6 months of the change?
Corrective Action(s):
Have all employees been trained and documented at least annually?
Corrective Action(s):
Are facility inspections being completed, at least monthly?
Corrective Action(s):
Are issues and deficiencies being corrected in a timely fashion?
Corrective Action(s):
Are training and inspection documentations retained for 3 years?
Corrective Action(s):
Are reportable spills documented and retained with the plan?
Corrective Action(s):
Is the SPCC plan reviewed by district management every 5 years?
Corrective Action(s):

Storm Water Pollution Prevention (SWPP) Plan

Does the facility meet the applicable state requirements for a SWPP plan?
Corrective Action(s):
Does the facility have an approved plan?
Corrective Action(s):
Does the facility qualify for a No Exposure permit or exemption?
Corrective Action(s):
Does the facility have to file for a no exposure permit?
Corrective Action(s):
Does the facility have an up to date permit/exemption?
Corrective Action(s):
Is the plan accurate with respect to current storm water run off trends and preventative measure?
Corrective Action(s):
Are changes to personnel and the facility updated in the plan with 6 months?
Corrective Action(s):
Are water drainage and run off areas free of oil, debris, etc.?
Corrective Action(s):

Secondary Containment

Are all oil containers inside, or on top of, secondary containment (including 5, 30, and partially filled containers)?
Corrective Action(s):
Is the secondary containment able to hold 110% of the volume of the largest container it is protecting?
Corrective Action(s):
Are all secondary containment a leak proof? If drain plugs are available, are they installed?
Corrective Action(s):
Are containments covered to prevent rainwater, trash, or other material from getting inside?
Corrective Action(s):
Are containments free of debris, old oil, water, etc. to allow for observance of a leak?
Corrective Action(s):
Are containers, buckets, and barrels in good condition, labelled, rust free, and sealed?
Corrective Action(s):
Are there empty buckets , barrels, totes, etc. on or inside containments that can be removed?
Corrective Action(s):

Chemical Inventory and Storage

Is the chemical inventory to high for the size and storage capability of the facility?
Corrective Action(s):
Are chemicals separated to allow for easy access?
Corrective Action(s):
Are chemicals stored based on hazardous properties (flammable materials in cabinets away from heat sources, water sensitive away from openings and water sources, etc.)?
Corrective Action(s):
Are there any RCRA category hazardous materials?
Corrective Action(s):
Are those clearly marked and easily identifiable?
Corrective Action(s):
Can they be replaced by something that is not a hazard, or at least, more safe?
Corrective Action(s):
Are there any expired chemicals?
Corrective Action(s):
Is there a system in place to minimize expiration of materials?
Corrective Action(s):
Are expired, unusable, or chemicals not intended for use properly removed, transferred, sold, or disposed of, in a timely manner?
Corrective Action(s):
Is there documentation to prove those transactions?
Corrective Action(s):
Are chemical transactions completed with certified and reputable companies?
Corrective Action(s):

Waste Management

Used Oil

Are used oils maintained in a leak proof container?
Corrective Action(s):
Is the used oil container properly labelled "Used Oil?"
Corrective Action(s):
Is it in a proper size secondary containment?
Corrective Action(s):
Is it sealed when not in use?
Corrective Action(s):
Are used oil filters properly stored until they are removed from the facility?
Corrective Action(s):
Is there documentation from a certified company verifying the removal of the old filters?
Corrective Action(s):

Separated Waste

Is household trash separated from oily rags, absorbents, clay granulas, etc.?
Corrective Action(s):
Are the separate containers clearly marked and easily distinguishable?
Corrective Action(s):
Are oily wastes, rags, etc. removed from the facility in a different manner (third party) than household garbage?
Corrective Action(s):
Is there documentation to verify its removal?
Corrective Action(s):
Is the company/person removing non-household trash certified and approved to do so?
Corrective Action(s):
Is there hazardous waste at the facility?
Corrective Action(s):
Are manifest with EPA I.d. Numbers available upon request?
Corrective Action(s):
Are manifests retained for 3 years if required?
Corrective Action(s):
Can the facility be considered a conditionally exempt small quantity generator? Less than 220 lbs. of hazardous waste generated per month and never more than 2200 lbs. stored at the facility?
Corrective Action(s):

Dumpster Management

Are dumpster doors and lids closed unless in use?
Corrective Action(s):
Is there evidence of oily materials being thrown away in household trash dumpsters?
Corrective Action(s):
Is the ground around the dumpster free of oil, or other uncleaned spills?
Corrective Action(s):

Maintenance Practices

Are precautions taken to minimize the amount of material spilled during maintenance (drip pans, impermeable layers above the ground, etc.)?
Corrective Action(s):
Are the appropriate tools for the job being used?
Corrective Action(s):
Is the appropriate layer of supervision or experience used to properly conduct maintenance?
Corrective Action(s):
Are equipment and tools properly stored when not in use?
Corrective Action(s):
Is there deliberate, thoughtful actions taking place during maintenance?
Corrective Action(s):
Is there communication between personnel involved to prevent accidents and maximize efficiency?
Corrective Action(s):

Wash Bay Construction and Use

Does the facility have a covered wash bay?
Corrective Action(s):
Does the wash bay have an oil water separator?
Corrective Action(s):
Is it routinely inspected for proper operation?
Corrective Action(s):
Are the inspections documented?
Corrective Action(s):
Does the water portion empty into a municipal sewer or water treatment facility?
Corrective Action(s):
Does the facility have a copy of the permit or certification to empty into the sewer or treatment system?
Corrective Action(s):
Does the water flow into a large above ground tank?
Corrective Action(s):
Does the tank have secondary containment?
Corrective Action(s):
Are the tank contents routinely removed by a certified company?
Corrective Action(s):
Is documentation available for the disposal of the waste water?
Corrective Action(s):
Does all of the liquid empty into underground tanks or sumps?
Corrective Action(s):
Is there a description or diagram available for the size and construction of the underground tanks?
Corrective Action(s):
Are these tanks routinely checked for level?
Corrective Action(s):
Are the contents of the tanks removed by a certified company?
Corrective Action(s):
Is there documentation available to demonstrate proper disposal of the waste water?
Corrective Action(s):
Is proper PPE used while in the wash bay?
Corrective Action(s):
Are proper precautions (fall protection, ladder use, handrails, etc.) used when climbing on equipment while working on or washing?
Corrective Action(s):
Are chemicals, oils, tools, etc. stored inside the wash bay?
Corrective Action(s):
Are wash bay drains routinely inspected and cleaned to prevent clogging and back up?
Corrective Action(s):
Are employees aware of the solvents, soaps, degreasers, etc. in use while in the wash bay, and the hazards associated with them?
Corrective Action(s):

MSDS and HAZCOM

Is there a Hazardous Communication System in place at the facility?
Corrective Action(s):
Is there document training conducted annually by all employees?
Corrective Action(s):
Is the a "Right to Know" station clearly visible and accessible?
Corrective Action(s):
Are there MSDS and binders clearly marked and easily accessible?
Corrective Action(s):
Is there an updated index with the chemicals associated with the facility neatly organized?
Corrective Action(s):
Are the MSDS the current one available?
Corrective Action(s):
Is there a system, or person, that periodically checks for new MSDS and updates the facility binder(s)?
Corrective Action(s):
Are employees trained when a MSDS is added, removed, or revised?
Corrective Action(s):