Ben Doornink
Far West Focus Magazine
Far West Agribusiness Association
Earlier this summer, I was invited to travel to southern Idaho to observe one of our members go through an EPA audit of its Risk Management Plan (RMP). Having never sat through an EPA audit before, I jumped at the opportunity. I arrived early to meet with our member company’s full-time Safety & Regulatory Manager and the Facility Manger. They walked me through their operations, from receiving anhydrous ammonia via rail, storing it in bulk, and how they contract with a third party to bring a portable reactor to convert anhydrous ammonia to liquid fertilizer.
The EPA auditors had another visit scheduled for that morning, so the audit was behind schedule when the group arrived. The EPA posse consisted of five individuals – four EPA Region 10 inspectors and an independent contractor whose responsibility it was to document the visit and summarize the findings. After introductions the audit started with a tour of the facility to familiarize the auditors with the site’s operations. The 8 of us were joined by the employee of the plant responsible for the anhydrous ammonia operations who answered questions from the auditor.
Following the 45-minute tour, we reconvened in the conference room so the auditors could review the RMP documentation.
Per their typical practice, each of the four EPA inspectors requested a different section of the RMP paperwork. This particular member kept its RMP documentation and files all in one binder, so the EPA inspectors were all requesting documents from the same binder. They split up the work to increase their efficiency in the review, but the well-intentioned plan had an unintentional side-effect: when they all review at the same time, they all have questions at the same time. The Safety Manager and the Facility Manager were constantly moving from topicto-topic as auditors each had questions and needed answers immediately.
When the auditors were satisfied that their questions had been answered, they left with the promise of summarizing their findings and getting back in touch with our member in the next three months to three years.
Reflecting back on this learning experience, I noticed three simple things that would help you to prepare for an RMP audit.
Be Prepared – Before the inspectors arrive, be sure to spend plenty of time reviewing your RMP paperwork. Make sure that nothing is missing. It might be a good idea to make copies of the documentation so the inspectors don’t have to work from a single binder. Brief the staff members who will be involved and have them prepare for questions that might arise.
Document Everything – Probably the biggest mistake that facilities make is to not document their actions. When you perform your worst-case scenario analysis, document when it was done, who did it, where the data came from, your methodologies, etc. When you test a tank, document it. When your individuals receive training, document it. When you review your RMP plan, document it. Document everything.
Cooperate – Remember, the inspectors are trained professionals. Taking your frustrations will get you nowhere. Be courteous, even if you may think the inspector is being unreasonable. You may not see things eye-to-eye, but be cordial. If you arrive at the audit with a large chip on your shoulder, you might make the inspector less willing to see things in your light.
This particular member has yet to hear back from EPA regarding the audit. One of the topics of discussion holding up the process is the use of third party contractors with mobile reactors and the related storage of anhydrous ammonia.
Observing this audit gave me valuable insight into the regulatory burden that our industry faces. At one point during the audit, an inspector asked the Facility Manager about the facility’s employee safety training program and he replied “We use Asmark for that”. The inspector’s affirming response was enough for me to realize the value of working with professionals to help agribusinesses be in compliance with all of these regulations.
Ben Doornink
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