EPA Audit Checklist: 15 Things to Fix Before They Show Up

An EPA inspector does not call ahead. They will pull into your parking lot on a Tuesday morning, walk into your front office, and hand someone a business card. At that point, you have roughly the time it takes to walk from the lobby to your operations area to get your documentation in order.

Most facilities aren't doing anything intentionally wrong. They're just not thinking about environmental compliance until someone forces them to. The items on this list are the things I've seen catch facility managers off guard over and over. Every single one of them is fixable in advance. Most of them cost nothing but a few hours of attention.

1. Your SPCC Plan Is Outdated

If your facility stores more than 1,320 gallons of oil in aboveground containers (or 42,000 gallons underground), you need a Spill Prevention, Control, and Countermeasure plan. Most facilities have one somewhere in a binder. The problem is that it was written in 2017 and nothing has been updated since.

Your SPCC plan needs to reflect current conditions. If you've added tanks, changed operations, moved storage locations, or had a spill, the plan needs to be amended. An inspector will compare what's on paper to what's on the ground. If they don't match, that's a finding.

2. Container Labels Are Missing or Wrong

Every container of waste needs to be labeled with its contents and the date accumulation started. Every container of product needs to identify what's inside. Walk through your facility right now and look at the drums sitting around. How many have legible labels? How many have any label at all?

Unlabeled containers are one of the most common violations because they're one of the easiest things to let slide. Fix this in an afternoon with a marker and some weatherproof labels.

3. Secondary Containment Is Compromised

Your secondary containment (berms, dikes, containment pallets) needs to be intact and functional. Cracks in concrete berms, holes in containment pallets, and drain plugs left open all count as failures. If there's rainwater sitting in your containment area, that's also a problem because it reduces your containment capacity.

4. Your Hazardous Waste Area Is a Mess

Satellite accumulation areas and 90-day storage areas have specific requirements. Containers must be closed when not actively adding waste. The area needs to be marked. Incompatible wastes need to be separated. If your waste area looks like a random collection of drums with no organization, you're going to have a bad day during an inspection.

5. Waste Profiles Are Expired

Waste profiles (the analytical characterization of your waste streams) typically expire annually. If you're shipping waste on expired profiles, you're out of compliance. Check with your waste disposal vendor to verify all active profiles are current. This is one of those invisible problems that doesn't become visible until an inspector or your disposal facility asks for documentation.

6. No Stormwater Sampling Records

If your facility has an NPDES permit, you're required to sample your stormwater outfalls on a specific schedule. Many facilities forget this or don't realize their permit requires it. No sampling records means no proof of compliance. An inspector will ask for your most recent results.

7. The OWS Hasn't Been Serviced

If you have an oil/water separator, it needs regular maintenance. Inspectors will ask when it was last cleaned and whether you have documentation. If your answer is "I don't know" or "I'm not sure we have one," that's a problem. Read our guide on OWS maintenance for the full breakdown.

8. Emergency Contact Info Is Missing

Your facility should have posted emergency contact information including your environmental services provider, fire department, and internal contacts. Inspectors look for this. It should be visible in your operations area, near chemical storage, and near your waste accumulation areas.

9. Training Records Don't Exist

If your employees handle hazardous waste, they need documented training. Not just verbal instructions. Actual documented, signed training records. RCRA, HAZWOPER, DOT if you ship, and facility-specific training all need paper trails. If someone asks "who trained your team on waste handling?" and the answer is "we showed them," that's not enough.

10. Used Oil Is Being Mismanaged

Used oil has its own set of regulations. It must be stored in approved containers, labeled "Used Oil," and never mixed with hazardous waste or solvents. Mixing used oil with anything else can change its classification and dramatically increase your disposal costs and liability.

11. No Spill Kit Near Storage Areas

Every area where chemicals or petroleum products are stored or used should have an accessible spill kit. The kit needs to be appropriate for the materials present (oil-only sorbents for petroleum, universal for mixed chemicals) and needs to be stocked, not empty from the last incident nobody replaced it after.

12. Drains Are Unidentified

Do you know where every floor drain in your facility goes? Storm? Sanitary? OWS? If you can't answer that question for every drain, you have a gap. An inspector may ask. More importantly, your team needs to know so they don't wash something down a drain that leads directly to a waterway.

13. Manifest Copies Are Missing

Hazardous waste manifests must be kept for at least three years. If you shipped hazardous waste and can't produce the signed manifest showing it was received at the disposal facility, you can't prove it was properly disposed of. Keep your manifests organized and accessible.

14. Air Permit Conditions Aren't Being Met

If your facility has an air emissions permit, there are conditions attached. Recordkeeping, maintenance schedules, emission limits, reporting deadlines. Many facilities get the permit and then forget about the ongoing requirements. Review your permit conditions at least annually.

15. Nobody Knows Who's Responsible

The most common root cause behind all of these issues is that environmental compliance doesn't have a clear owner at the facility. It's "everybody's job," which means it's nobody's job. Assign one person as the environmental compliance lead, even if it's only 10% of their role. Give them the authority to fix problems and the budget to maintain compliance.