Hazardous Waste:

Facility Inspections Are Not Thorough and Complete

RCED-88-20: Published: Nov 17, 1987. Publicly Released: Dec 16, 1987.

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Pursuant to a congressional request, GAO examined the thoroughness and completeness of hazardous waste handler inspections conducted by the Environmental Protection Agency (EPA) and authorized states under the Resource Conservation and Recovery Act (RCRA).

GAO found that: (1) EPA inspection experts identified 200 RCRA violations at 22 of 26 facilities inspected between December 1986 and May 1987; (2) initial inspections failed to detect an additional 181 violations at those facilities; (3) two-thirds of missed violations represented immediate and serious environmental threats; and (4) 15 inspection reports were incomplete. GAO also found that: (1) EPA inspection guidance was incomplete; (2) EPA has not established specific qualification standards for RCRA inspectors or continuing and mandatory inspector training programs; (3) lack of training significantly contributed to poor inspector performance; (4) RCRA inspections received limited oversight; and (5) EPA is reconsidering its elimination of an oversight target for regional offices and is also reevaluating how best to ensure the thoroughness and completeness of RCRA inspections.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: Under recent changes, EPA headquarters' regional program reviews focus on broad, rather than specific issues. Because state inspection performance has improved since GAO report RCED-88-20, EPA does not consider this a problem anymore.

    Recommendation: To ensure that thorough and complete inspections are conducted and that information on inspection quality is available for use in determining the frequency of future oversight inspections, and in developing and assessing inspector training needs, the Administrator, EPA, should reinstate the requirement that regional oversight of state RCRA inspections be evaluated and reported in headquarters' regional program reviews.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: The 10-percent target requirement has been reinstated in the EPA 1989 Regional Implementation Plan (RIP). The 1989 RIP also provides that regions consider state inspection performance in reviewing state grants.

    Recommendation: To ensure that thorough and complete inspections are conducted and that information on inspection quality is available for use in determining the frequency of future oversight inspections, and in developing and assessing inspector training needs, the Administrator, EPA, should reinstate the target requirement that regions annually oversee 10 percent of state RCRA inspections and ensure that state performance in conducting these inspections is addressed in state grant reviews performed by the regional offices.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA has developed a RCRA inspection training program, which is mandatory for EPA inspectors and recommended to state inspectors.

    Recommendation: The Administrator, EPA, should develop and implement a continuing and mandatory RCRA inspector training program.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: EPA has issued the scheduled inspection guidance documents. However, EPA does not plan to issue regulations because it believes the guidance documents provide adequate direction on conducting effective RCRA inspections.

    Recommendation: The Administrator, EPA, should ensure that inspection guidance and regulations on how to conduct inspections are issued as scheduled.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Not Implemented

    Comments: Because overall inspection performance has improved since GAO report RCED-88-20, EPA does not consider this a problem warranting specific action.

    Recommendation: To ensure that thorough and complete inspections are conducted and that information on inspection quality is available for use in determining the frequency of future oversight inspections, and in developing and assessing inspector training needs, the Administrator, EPA, should develop and implement a system to provide routine oversight over EPA regional and EPA contractor inspections, as well as documenting and reporting the results to EPA headquarters.

    Agency Affected: Environmental Protection Agency

 

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