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Low Priority for Routine Inspections

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One of the benefits offered through Performance Track is EPA's commitment to consider all participating facilities as "low priority for routine federal EPA inspections." Routine inspections are generally those that occur when there is no specific reason to believe that a violation exists at a specific facility. The Performance Track policy regarding low priority for routine inspection is limited to federal inspections, and while most routine inspections are conducted by state and local authorities, EPA encourages state enforcement programs to honor this policy as well.

EPA provides this low inspection priority status since the performance- and compliance-focused environmental management systems (EMSs) implemented by Performance Track members, coupled with periodic EMS and compliance auditing, should help prevent non-compliance at Performance Track facilities. As a designated low inspection priority facility, members save the resources and time regularly spent preparing for and responding to inspection requests.

"Low priority for routine inspections" should not be interpreted to mean that EPA should not inspect PT facilities. In certain situations, EPA could inspect Performance Track facilities where the Agency has information that serious problems may exist. Examples of such problems are criminal activity, major compliance problems in a priority area of concern to the Agency, or endangerment.

EPA has issued several memos detailing this policy initiative:

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