The Office of Compliance and Federal Facilities Enforcement Office have slightly different definitions of multi-media inspection. The Office of Federal Activities developed a more limited definition.
The National Enforcement Investigations Center (NEIC) generally only conducts multi-media inspections and they have developed a multi-media inspection manual to follow. Office of Compliance follows a more general definition of multi-media inspection. The following is excerpted from a multi-media training course developed in 1995 and was provided by Kenneth Gigliello, Associate Director, OC's Compliance Assessment & Media Programs Division.
What determines a multi-media inspections?
- Term "multi-media" refers to all environmental programs and all related environmental laws and regulations.
- Multi-media inspections use a broad spectrum of available approaches to motivate compliance and monitor and control threats to human health and the environment.
- Inspectors use tools based on all environmental statutes for which EPA has responsibility.
- A holistic approach should be taken during a multi-media inspection which involves considering the facility as a whole by understanding the process(es) and not limiting the scope of the inspection to any single statute or set of regulations.
- Multi-media inspections can be tailored to meet the needs of EPA in determining the compliance status of the facility. Many factors enter into the decision about how complex or how simple a multi-media inspection should be.
- Multi-media inspections should emphasize the identification of violations, permits, orders and consent decrees, as well as the underlying causes of such violations.
- The two general approaches used are 1) Trained generalist (mainly used for smaller, less complex facilities such as dry cleaners, auto service and repair, etc.) and 2) the Team Approach (more applicable to chemical plants, refineries, large manufacturers, etc.).
Does a multi-media inspection have to include any of the major programs (Air, RCRA, Water)?
- Not necessarily, since an individual Region may determine that other media programs are more appropriate for a specific facility.
- It would be difficult to justify expending resources to conduct a multi-media inspection without including at least one of the three major programs since most facilities are subject to either air, water, and waste regulations.
- At an absolute minimum, a multi-media inspection must include a compliance review of at least two media programs from the following list (RCRA, CAA, CWA, TSCA, SDWA, CERCLA, EPCRA, FIFRA, MCBRMA, AHERA, MPRSA).
- The ICIS database has the data fields that allow the user to enter a separate inspection for each media program associated with the inspection. Each inspection record will count.
The definition of what constitutes a Federal facility multi-media inspection for purpose of annual work commitments is defined in the OECA National Program Managers Guidance which can be found at this link http://www.epa.gov/ocfo/npmguidance/index.htm. The definition taken from in the FY2005-07 guidance (dated May 19, 2004) reads as follows:
A federal facility multi-media inspection consists of (1) a CAA, CWA, or RCRA program inspection plus at least one additional program under a different statute for the same facility; or (2) some combination of two or more CAA, CWA, or RCRA program inspections at the same facility. To count as a multi-media inspection, no more than three months may have elapsed between an inspection by one program and subsequent inspection by another program.