The EPA – General Duty Inspection Checklist is outreach material that traditionally handed out at events. It use to be posted under the EPA Region 7 website. As far as we can find, we can’t find any other region whom has GDC Inspections formally published. If you have one from another EPA region, we would like a copy!
So what does this mean? Do you operate a facility with less than 10,000 lbs of Ammonia? If so, this is the checklist that EPA would use in Region 7 for an inspection. Note that unlike how the RMP Inspection checklist is used, where the information on all pages can constitute a violation, most of the pages of the GDC checklist are prompts to help the inspector get a fuller view of what the facility is doing to identify hazards using appropriate hazard assessment techniques, design and maintain a safe facility, and minimize consequences of accidents that do occur. These latter three (and the questions listed on page 21 of the inspection checklist) are the obligations under the General Duty Clause, and those are the specific violations that EPA can assess at a facility under GDC.
Under the Clean Air Act Section 112(r)(1), the General Duty Clause states: “The owners and operators of stationary sources producing, processing, handling or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the general duty clause in the Occupational Safety and Health Act (OSHA)] to identify hazards which may result from (such) releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.”
