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

An EPA inspector does not call ahead. They pull into your parking lot, walk into your front office, and ask to speak with whoever manages environmental compliance. You have about 5 minutes to get yourself together before they start walking the site. That is not enough time to fix anything. It is enough time to panic.

I have been on-site during three EPA inspections and dozens of state-level audits. The pattern is always the same. They check the same things every time. If you know what those things are, you can fix them before anyone shows up.

Here are the 15 items they look at first, ranked by how often I have seen facilities get cited for them.

1. Container Labels

Every container of hazardous waste needs a label that says "Hazardous Waste" along with the contents, the hazard code, and the accumulation start date. Every single one. I have seen $37,500 fines for unlabeled 5-gallon buckets. The inspector will walk your storage area and look at every container. If even one is missing a label, that is a violation.

2. Accumulation Start Dates

When you start putting waste into a container, you write the date on it. Large quantity generators (LQGs) have 90 days to ship it off-site. Small quantity generators (SQGs) get 270 days. If your date is past the limit, or if there is no date at all, you are out of compliance. Inspectors check every date on every container. Bring a marker.

3. Secondary Containment

Every hazardous waste storage area needs secondary containment. That means a berm, dike, or containment pallet that can hold 110% of the largest container or 10% of total volume, whichever is greater. The containment has to be free of cracks, and it cannot have a drain unless that drain goes to a permitted treatment system. Rainwater sitting in your containment is a red flag because it means nobody is managing it.

4. SPCC Plan

If your facility stores more than 1,320 gallons of oil above ground (counting all containers 55 gallons and larger), you need a Spill Prevention, Control, and Countermeasure plan. It must be on-site, reviewed every 5 years, and certified by a Professional Engineer if your total capacity exceeds 10,000 gallons. The inspector will ask to see it. If you hand them a dusty binder from 2018, expect follow-up questions.

5. Weekly Hazardous Waste Inspections

LQGs must inspect their hazardous waste storage areas weekly. SQGs must inspect on a schedule they define. Either way, you need written inspection logs with dates, the inspector's name, and notes on anything found. No logs means no proof you inspected. No proof means a violation.

6. Waste Profiles

Every waste stream leaving your facility needs a valid waste profile. Profiles expire, usually every 1 to 5 years depending on your disposal facility's requirements. An expired profile means you are shipping waste without proper characterization. That is a RCRA violation, and the disposal facility can reject your shipment, leaving you with waste on a truck and no place to take it.

7. Hazardous Waste Manifest Records

You must keep copies of every hazardous waste manifest for at least 3 years. Most states require longer. The inspector will ask to see your manifest files. They will check that every manifest has a signed copy back from the disposal facility (the "return copy"). If you shipped waste 60 days ago and do not have the return copy, you are required to file an exception report with the EPA. Almost nobody does this.

8. Emergency Action Plan

Your facility needs a contingency plan that covers what to do in a spill, fire, or explosion involving hazardous materials. It must include emergency coordinator contact information (with 24-hour phone numbers), evacuation routes, and arrangements with local emergency responders. The plan must be submitted to your local fire department. The inspector may call your fire department to confirm they have a copy.

9. Stormwater Outfalls

The inspector will walk your stormwater outfalls. They are looking for oil sheen, discoloration, foam, or debris. If your facility has an industrial stormwater permit, they will want to see your sampling records, your Stormwater Pollution Prevention Plan (SWPPP), and evidence of quarterly visual inspections. A sheen at your outfall during an inspection is one of the worst-case scenarios because it is visual proof of a discharge.

10. Tank Integrity

Above-ground storage tanks need to be in good condition. That means no visible rust-through, no staining on the ground underneath, no missing or damaged valves, and no evidence of leaks. If you have a tank that is visibly corroded, get it replaced or repaired before someone official sees it. Tank failures cause some of the most expensive cleanups in the environmental services industry.

11. Training Records

RCRA requires hazardous waste training within 6 months of hire and annual refresher training after that. You need written records with the employee's name, training date, topics covered, and the trainer's name. If your last training was 18 months ago, you are out of compliance for every employee at the facility.

12. Generator Status

Do you know whether your facility is a Large Quantity Generator, Small Quantity Generator, or Very Small Quantity Generator? Your EPA ID number reflects a status, and your obligations change dramatically between categories. An LQG has far more requirements than a VSQG. If your waste volumes have changed and you have not updated your status, you may be operating under the wrong set of rules.

13. Satellite Accumulation Areas

You can keep up to 55 gallons of hazardous waste (or one quart of acutely hazardous waste) at or near the point of generation without a permit. These satellite accumulation areas have their own rules: containers must be in good condition, compatible with the waste, kept closed except when adding or removing waste, and labeled with contents. Once you hit 55 gallons, you have 3 days to move it to your main storage area and start the accumulation clock.

14. Universal Waste

Fluorescent bulbs, batteries, mercury-containing devices, and certain pesticides are "universal waste." They have their own set of regulations that are simpler than full RCRA, but you still have to label them, date them, and ship them within one year. I have seen facilities with boxes of spent fluorescent tubes stacked in a corner with no labels and no dates going back years. That is a violation.

15. Air Permits and Emissions

If your facility has a paint booth, welding operation, solvent cleaning, or any process that emits volatile organic compounds (VOCs) or hazardous air pollutants (HAPs), you likely need an air permit. Inspectors sometimes check whether your actual operations match your permitted operations. If you added a process or changed a chemical and did not update your permit, you could be operating without proper authorization.

The Walk-Through Pattern

Every inspector I have seen follows the same general pattern. They start in the office and ask for your files: SPCC plan, contingency plan, manifests, training records, inspection logs. They review paperwork for 30 to 60 minutes. Then they walk the site.

Outside, they hit the loading docks first, then the waste storage areas, then the stormwater outfalls, then the tank farm. They photograph everything. They take notes. They ask your escort questions designed to reveal whether your people actually understand the compliance requirements or are just going through the motions.

The best thing you can do is walk this same route yourself every month. Look at your facility the way an inspector would. If something catches your eye, it will catch theirs.

Want to check your state's penalty structure? Use our 50-state penalties lookup tool to see what environmental violations cost in your state.