COVID-19 and the associated shelter-in-place orders caused the temporary shutdown of operations at some facilities. This raised a number of questions regarding how to document temporary facility closures for routine inspections. During our Environmental Leadership Panel webinar, Amy of Recology and Todd of Oldcastle, both noted documentation was key for programs during COVID-19. While regulatory agencies are generally exercising enforcement discretion, it is critical to note exceptions that occurred. For example, if your facility is closed for multiple months, many permits have temporary suspension provisions. However, it may be easier to document the monthly inspection as not being done due to a shut down. Facilities should check with their EHS teams, legal counsel, and/or regulators on how to handle and document each situation.
Mapistry Inspection Forms – Noting Exceptions
In Mapistry, you could note the exception on the first page of the inspection form. For some, they will use the exception that the inspection was not done and state “Facility shutdown due to shelter-in-place, no industrial activities are occurring.”
Next, Mapistry customers can go into the industrial areas and Best Management Practices (BMP) sections and delete the pre-filled BMPs. This way you are not certifying that you saw those BMPs, but still documenting your monthly obligation to complete an inspection. From a metrics standpoint, your inspection completion rate will reflect that you completed the inspection. However, the form will show the inspection was an exception due to a facility shutdown that made it unsafe (e.g. public health concerns) to conduct the inspection.
Robust Inspection Programs
Completing inspections and noting exceptions is the first part of a robust inspection program that is focused on meeting the minimum requirements for regulatory compliance. For more on inspection programs, you can check out our helpful guide to the Three Phases of a Successful Inspection Program. As always, if you have any questions please feel free to reach out to us at firstname.lastname@example.org