Key steps to successfully pass ESOHCAMP audit

  • Published
  • By 23rd Civil Engineer Squadron environmental division
MOODY AIR FORCE BASE, Ga. --  Editor's note: This is part of a series of articles to help prepare Moody members for this audit.

A "no-notice" auditing program has been scheduled on Moody for early 2010 to evaluate the base's compliance with local, state and federal environmental, safety and occupational health laws.

Air Combat Command's External Environmental, Safety, Occupational, Health, Compliance, Management Program assessment (ESOHCAMP), is an audit which consists of an inspection of facilities, processes, procedures, protocols, records, and documentation of records, reports and incidents as well as a review of all pertinent training documentation.

The audit also consists of interviews with shop commanders as well as shop personnel in order to evaluate and assess compliance. The auditors assess compliance through a scale rating system.

Each shop begins with 100 points and any penalties will cause a deduction of points.

The lists below are additional tops to ensure the audit is passed.

Here are three simple steps to help walk auditors through each shop:

- Respectfully and factually answer all of the auditors' questions in regards to processes, procedures and protocols. Simply but thoroughly discuss operations so they can understand what the shop is responsible for handling and generating.
- Respectfully and directly escort them to all pertinent shop areas to verify processes, procedures and protocols. Seek personnel assistance for shop details.
- Respectfully and accurately present all records and documentation to verify processes, procedures and protocols.

Eight of the 15 most common ESOHCAMP findings are documentation related. Regulators and auditors cannot be on-hand continuously evaluating compliance; therefore, documentation is the process through which compliance is validated.

Regulations are written specifically requesting the documentation process for this very reason.

Here are documents auditors will be looking for:
- Current hazardous waste determinations
- Current used oil, universal waste and nonhazardous waste determinations
- Current training records, including certificates, rosters and hazardous waste operator's training
- Current written operational plans, including spill prevention countermeasures and control plan, waste management plan, environmental management system, integrated contingency plan, master entry plans and hazard communications
- Current shipping documents including hazardous waste manifests and bill-of-lading
- Current regulatory required certifications, including land disposal restrictions and certificate of destruction
- Current and appropriate use of material safety data sheets, labels and required signs (including No Smoking, Hazardous- Keep Out, Authorized Personnel Only, Satellite Accumulation Point)

Here are other significant aspects auditors will inspect:
- Accurate labeling with the date noting the first date of accumulation written on it
- Containers holding hazardous waste, solid waste, universal waste, used oil, new products and reused containers
- Lockers, including flammable cabinets and contents
- Binders and documentation folders

All containers will be evaluated for their conformance. This includes all drums, trashcans, five-gallon buckets, used rag cans, dumpsters and every other type of container.

Lids on all containers must be kept closed except when adding or removing waste.

Refresher training should be conducted for all individuals. Document all training in electronic files and keep rosters or copies on-hand if possible. Also, all shops should review and update hazardous communications and training programs and plans.

Please contact any of the individuals below with questions or concerns. For environmental questions, call Elvis Lane, Greg Haugen or Bill Fowler at (229) 257-3849/4654/1395. For bioenvironmental questions, call Susan Cordova at (229) 257-4747. For natural resources questions, call Gregory Lee at (229) 257-5881. For additional safety questions, call (229) 257-3082.