Environmental Health and Radiation Safety regulatory
agencies may make unannounced inspections of University of
Pennsylvania facilities from time to time. Regulatory
agencies generally have authority to enter public or private
property connected with an activity governed by a permit or
regulation. These regulatory agencies include the Pennsylvania
Department of Environmental Protection (DEP),
the Environmental Protection
Agency (EPA), the Nuclear
Regulatory Commission (NRC), the Occupational
Safety and Health Administration (OSHA), and
Philadelphia agencies including, the Fire Department, Air
Management Services and Licenses & Inspections
(L&I). Inspections may be conducted for a number of
reasons, including: response to employee or community
complaints, response to noncompliance activities,
investigation of conditions related to pollutant discharge,
records review, errors or violations in compliance reports,
fact-finding in support of a permit application filed by a
facility, periodic visits as mandated by Agency inspection
procedures, etc.
Increasingly, regulators conduct "multimedia"
inspections. Multimedia environmental compliance inspections
are conducted by a team of specialists who simultaneously
review all air, water and waste compliance related issues.
Inspections typically include a facility walk-through
focused upon the work areas, records review, personnel
interviews, measurements, tests, or sampling activities.
Because the nature and purpose of Agency inspections is
highly variable, there is no single procedure or protocol
for regulatory agency interaction during visits. This fact
sheet is designed to provide facility personnel with general
guidance in responding to environmental agency compliance
inspections.
Environmental Health
and Radiation Safety: Phone....215.898.4453; FAX
....215.898.0140
Office of the General
Counsel: Phone....215.746.5200; FAX....215.746.5222