You may think your plant adheres to all the environmental, safety and health regulations issued by the various branches of government, but how can you be sure? One way is to undergo an NAA Regulatory Compliance Audit. The NAA audit consists of four phases:

1. A conference session with the newspaper's environmental, safety and health managers to discuss the status of the programs listed below. Federal, state and local regulations are reviewed.
2. A walk-through plant inspection. An NAA industrial hygienist identifies areas in need of improvement and takes Polaroid pictures to document problems. The pictures are returned to the newspaper with the report.
3. A debriefing with the publisher and/or program managers as appropriate.
4. Report preparation. The report is a synopsis of regulations, observations and recommendations. In addition, an extensive appendix is provided which contains compliance information such as checklists and regulations.

Here are details on just a few of the programs included in an audit:

Hearing Conservation:

• Noise survey
• Employee audiograms
• Hearing test booth/audiometric-test-equipment-calibration records
• Employee hearing-loss records
• Standard threshold shift
• Ear plugs & muffs (personal protective equipment)
• Hearing-protection evaluation
• Noise standard posted
• Noise signs
• Noise-training programs

Hazard Communication:

• Written program
• Master and departmental HazCom binders
• Material Safety Data Sheets
• Chemical-product list
• Training program
• Labeling
• Contractor provision
• Non-routine tasks

General Plant Safety:

• Overall safety policy and program
• Safety committee
• Emergency medical policy/procedures
• Emergency action plan
• Blocked escape routes
• Locked doors
• Lighted exit signs
• Machine guarding
• Walking and working surfaces
• OSHA posters
• PPE Worksite Evaluation

Fire Safety:

• Evacuation plan
• Evacuation diagrams
• Fire drills
• Zones outside
• Fire inspections
• Sprinklers
• Heat and smoke detectors
• Annunciator panels
• Fire extinguishers
• Halon (CFCs)

Waste Management and Minimization:

• Overall waste-management policy
• EPA hazardous-waste-generator identification number
• Waste-shipment records (manifests)
• Employee-training records
• Contingency plan (SPCC)
• Waste-disposal facility records
• Industrial-laundry records
• EPA inspection records
• Waste-analysis reports
• EPA biennial reports
• Recycling.

Other programs: Record Keeping, Air-Pollution Control, Waste Water, DOT Training, Emergency Planning and Community Right-to-Know, Lockout/ Tagout, Fleet Safety and Powered Industrial Trucks, Underground Storage Tanks, Government Liaison, Storm-Water Discharge, Ergonomics, Indoor Air Quality, Blood-borne Pathogens and Confined-Space Entry.

For more information on audits, call Don Hensel, NAA manager of environmental services, at (703) 648-1215 or email naanetwork!naa!hensd@naaatt.attmail.com .

TechNews Volume 1, Number 5: September/October 1995

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