All About MECP Inspecting Businesses for Environmental Permits
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It is not uncommon to find yourself in a situation when a routine (unannounced!) MECP (short for Ministry of Environment, Conservation, and Parks) inspection reveals that your facility or operation is not compliant.
This may be due to missing certain environmental permits, such as the ECA (Environmental Compliance Approval) or the EASR (Environmental Sector and Activity Registry) permit, whichever of the two your operation may require.
As a company focusing on environmental permitting consulting services, we can say there is roughly 75% of businesses in Ontario that do not have the permits, up-to-date permits or are not fully abiding by the Terms and Conditions of their permit and will fail this inspection as a result of that.
If your facility was inspected and required to submit an ECA or EASR application, it is critically important to complete this application as soon as possible. You will need the assistance of an environmental permit consultant for that as this is often a complex process and easy to get wrong. It is also likely that the MECP will have set a deadline to complete your EASR registration or ECA application if you have failed an inspection.
Reasons for an MECP Inspection of Your Facility
The main objective of this inspection is to ensure compliance of your operation with Ontario’s environmental regulations, the Environmental Protection Act, and OReg’s 1/17 and 419/05.
The reasons for your facility to be chosen for the inspection, however, may vary.
They may include the following:
- You requested an environmental approval, such as the ECA or EASR
- A routine site inspection or random inspection
- Responding to a public complaint or request by another government agency (e.g., Ministry of Labour)
- A simple follow-up visit for a previous inspection which found violations
Those last two cases are when the EO (environmental officer) is most likely to arrive unannounced. Any spill or unregulated/unauthorized release into the environment is treated with all seriousness. Which is another reason to have an environmental permit consultant on your team at all times, and especially in times of a system failure such as a spill.
What to Expect During the Inspection
The environmental officer inspecting the facility will be mostly collecting information to evaluate the level of compliance with environmental regulations.
They are most likely going to interview your staff, tour the facility, collect samples, review records, and take photographs. They will compare your operational data to the limits stated in your permit (if you have one), and ask to see documentation of compliance with the Terms and Conditions of your permit.
Depending on your operation’s nature and the purpose of the inspection, they may also inspect waste management systems, waterway discharge points, air emissions, and filtration systems, and more.
An environmental permit consultant will be able to give you a full list of those relevant to your facility or operation.
Ways to Prepare for the Inspection
To be sure, this is an overview of what you may need to do but a full preparation can only be guaranteed if you speak to your environmental impact assessment consultant prior to the EO arriving at the facility.
Here are a few key things to look for, however:
- Make sure you know all of your facility’s operations related to discharge, air, water, and so on.
- Find out and prepare all permits and approvals your operation may require.
- Maintain a set of clear, organized and easily accessible environmental records
- Hire and frequently touch base with your environmental permit consultant
Please don’t hesitate with us and get the assistance of our firm if you need an environmental permit consultant.