CESQG Business Inspections

Musings, Observations & Recommendations

Dave WaddellField Inspector,Question

Answerer, Project

Coordinator, Science Lab Guru,Smartass

With the LHWMP in King County

Why Am I Here?

• 10 years as a lead field inspector for LHWMP

• Our inspectors visited 3,000+ businesses/year

• Abby asked me to describe a mature inspection program

• I, of course, won’t stay on topic

Today’s Topics

• Why inspect sites?• Some approaches to

consider• Are inspections effective?• How not to mess up and…

– Get injured – Piss off your site guide– Tick off other inspectors

• We’ve adapted to changed priorities in the LHWMP

Why Inspect Businesses?

• Puts a face to your agency– Hopefully: helpful &

competent

• Clarifies who is posing risks to the local environment

• Most people want to do the right thing

• Most businesses don’t know what that is

• Questions answered specifically & immediately

A Note on Small Business Owners

• Often love their jobs & excel at them

• They work long hours• They have little free time• 75% of small businesses

go under in 1st 5 years• You aren’t their top

priority• We’re all from the EPA

– Don’t sweat that

Small businesses hit hard by recessionSo be a bit compassionate

Some Approaches to Consider (They’re varied – so vary your

technique)• Cold calling in priority areas/industries• Respond to referrals from agencies • Respond to chemical problem reports • Inspect priority businesses• No cash incentives without a visit• Technical assistance, not enforcement

– Still regulatory, but they’re “exempt”

Are Inspections Effective?

• Concerns over cost of staff vs. benefits

• People can only visit so many sites

• Would it be better to just mail out the info?– And pray someone

actually reads it. . .– And gets it . . .– And does something …

Never confuse movement with action

-Ernest Hemingway• How many inspections did you do?• Counting beans is not a primary job

– Waddell’s Business Card Inspections Technique

• But it is one indicator of progress

So, who should we inspect?Beware inaccurate industry

lists • Locating businesses to inspect by industry type• 25 to 35% error rate is common• Wasted visits to vacant lots

Impact Indicators (Outcomes)

• You were busy. So what?

• Need to show tangible results from activities

• Quantitative or anecdotal – Pounds no longer released– Lives potentially saved

• Tell a good story• Use photos

Measurement Assumptions

• Most owners are honest• They don’t minimize

generation rate estimates

• Field staff can verify info– Field observations– Shipping documents

• When in doubt, pregnant pause & skeptical eyebrow

So Bob, where DOES your waste antifreeze go?

Follow-ups

• Revisit the site if– Numerous problems– Significant opportunities

• Telephone follow-up if– Few waste mgmt. issues

• No follow-up– Compliant w/ little waste

Inspector Accomplishments Done in one year by six inspectors

• 436 visits• 12,400 pounds no longer being generated • 20,500 pounds diverted to proper

disposal• 4500 gallons of haz liquids stored safely• $9,000 saved by businesses • 97% of CESQGs initially non-compliant• 68% improved compliance w/ BMP’s

Use Photo Documentation

Sell Your Inspection Program Before After

Use Behavior Change Principles

To Make Inspections Effective• Inspector’s job = changing behavior• Brochure:

– “Properly store containers!”– Generalized and vague

• Inspector– “Move that drum away from that door

to that location in that secondary container”

– Specific and very clear

Can They Properly Manage Unknowns?

• Discuss in terms of loss– Injuries, lawsuits, testing

costs

• These could cost a fortune!• Can’t respond to spills• Can’t guarantee proper

protective equipment• Can’t dispose of it properly

– Very expensive to test

Voucher Incentive ProgramLeveraging their fees back into action

• Portion of biz fees rebated– 50% of costs up to $500

• Requires a site inspection – Can be request or referral– Must follow guidance– Submit invoices, manifests, form

• For each $1.00 of ours, they do $4.00 in work

• Over $1,000,0000 distributed

How Not To Mess Up…and get injured

• Keep eyes open & wits about you

• Pause before opening doors or moving bottles

• The common chemicals often cause most injuries

Familiarity breeds contempt – and children. –Mark Twain

Where’s the goggles,gloves, lab coat?

Recognize Unsafe SituationsFlammable storage by gas water heaters

Be prepared in case of an accident

Is this their eye wash?

Bad Dogs & “Whack-job” Site Guides

Inspectors need a variety of trainings

How Not To Mess Up . . .and piss off your site guide

• Don’t ask “What idiot labeled this?” It may be them.

• This conversation is over• Get beside them & look at issue• Ask probing question, then

pause • “You have an MSDS for your

Methol Something?”– They’ll blurt out something– Now we’re working together

Other Ways To Make Eyes Roll

• “We’ve targeted you for visits”

• Tell them to invest $50,000 in a treatment system– His profit last year was $20,000

• Quote regs• Use acronyms• Point out problems without

suggesting solutions• Paint the whole industry with

one brush

How Not To Tick Off Other Inspectors

Etiquette During Joint Visits• Decide up front who is lead investigator

– They do most talking & answer questions– Observer can also ask, just wait your turn

• If you disagree on a point, 2 options:– Wait till you can discuss it away from guide– If serious, gracefully avoid undermining

• Observer can catch items that were missed

• Afterwards, compare & refine notes

Collector Mentality

• HHW Collection staff look at this and ask:– What do you want

to get rid of?

• They then collect it• Process it• Dispose of it• Safely, legally and

securely

Inspector Mentality

• An inspector looks at this and asks:– What do you use?– Why do you use it?– How much do you use?– Tried alternatives?

• They then get it properly stored/handled/disposed

• In school cleanouts, this = 50% more old chems gone

Changing times = changed priorities in the LHWMP

• Manufacturing & heavy machining leaving• High tech influx• Small biz turnover high• Less improper disposal• Illegal dumping up• PBTs don’t fit very well• P2 messages morphing • How does product stewardship fit in here?

We’ve Changed Our Approach

• Working upstream to prevent problems– Change chemical policy– Push product

stewardship

• Shifting inspectors time to support these efforts

• Increasing partnerships• Cut our inspections

>60%

Lastly, always dress professionally