Thanks for posting that link Mark. It is a good read.
The unannounced “inspection” report was well done. Thorough. Reminded me of my previous life. Inspections like this are for the most part routine and conform to a schedule....say every 5 years. Exact dates are never announced unless special circumstances trigger it. An example would be an allegation, incident or an enforcement action by another agency. Not exactly a “Roger Stone” moment but close. “Good Moring Sir, We’re from the Gummint and we are here to inspect your facility and operation. Say, nice looking black truck out front. Is that yours?”
IME, this is the beginning of a long journey and the destination is not the Sandals Resort. Inspectors do their home work and I’d bet they already knew many answers before they asked a question. I sure knew a lot more about a licensee’s OPS and business than the contact thought I did. The licensee’s reluctance to fully and truthfully answer questions or to answer with a lot of hand waving and BS is always a big clue that something is hinky. “Company X” “Can’t tell you about the stealth owner of Company X” “Protecting privacy of a customer” “Don’t know who owns the red truck” “Owned by company X” Really? Agreement forms that can’t be printed? Really? Product boxes on a shelf and one of Santa’s Elves bumbling about? Well, My,My,My! How interesting. My retired BS antennas were tingling just reading that report.
So, photos, visual observations, confirmatory data collection......the dreaded “If we have questions and need to confirm with you our findings today, you won’t mind if we telephone you....would you? We just want to get the report straight...”. We’ll have a final report in 45 days, or less. And by the way, there is a real possibility that we’ll have an Enforcement Conference as the result of this Inspection. Thanks for helping us and have a nice day, Sir.....
I’d not be surprised if they pulled a follow up visit to “collect” more information and some product for confirmatory lab analysis. Might depend on whether or not the EPA Region 5 senses that they are being flimflammed or there are material false statements by the company representatives. Or, they could be moving to an enforcement action.