Inspections, notification requirements

The purchaser will specify the extent of his participation in the inspection and testing and the amount of advance notification required. 

P071 Days Notification Required Final Shop Inspection DAYS FI N 3 Day... 

Casing, 0 Final Inspection Required O Days Notification Required ... 

The notice of inspection may limit the inspection to one TSCA program. For example, the inspection could be limited to compliance with 8(e) requirements to submit notices of significant risk information, it could be directed to the premanufacture notification requirements of 5, or it could cover all TSCA requirements. The letter will typically specify the kinds of documentation that the inspectors will want to inspect. It is advisable to review these materials in advance to see exactly what the inspector will see, and avoid the element of surprise if there is a violation on the face of a document. It will often be possible to refute any inference of a violation, and all the arguments should be marshaled at this point. For example, if the inspection notice states that all notices of export under 12(b) should be assembled, and a quick review shows that some letters were not submitted until after the export may have taken place, it may be possible to gather documentation showing that the exports occurred later than expected and the notices were indeed timely. 

In the 2006 Proposal, EPA requested comment on, but did not propose, a requirement that renovation firms notify EPA before beginning a covered renovation project. Most commenters supported a notification requirement, arguing notifications would provide information to EPA about where renovation activities will be occurring, so EPA could inspect ongoing renovation projects for compliance with the requirements of this rule. These commenters stated that EPA would be unable to enforce the requirements of the rule without a notification provision. Some commenters also suggested that the act of informing EPA of their activities provides a powerful incentive for renovation firms to comply. 

Witnessed means that a hold shall be apphed to the production schedule and that the inspection or test shall be carried out with the purchaser or his representative in attendance. For mechanical running or performance tests, written notification of a successful preliminary test is required. 

However, the French legislation differs from the Austrahan legislation in one significant respect it does not require the consent of the owner of a facihty (or alternatively a warrant) in order to conduct an inspection. For routine inspections, the only requirement is notification to the owner. ... 

Substances supplied at <10 kg a are exempt from notification, but individual Member States may choose to require appropriate technical and commercial data to be submitted. Substances supplied at <100 kg a for scientific research and development are exempt from notification, but records of supply to customers must be available for inspection by the national Competent Authority. Substances can be supplied for process-orientated research and development to a limited number of registoed customers without tonnage limit for up to 1 year (extended to 2 years if justifiable). Individual Member States can decide what information is required, up to the maximum requirement for limited notification . If substances supplied under these three exemption categories are provisionally classified as very toxic , toxic , carcinogenic , toxic for reproduction or... 

Section 15 of TSCA, entitled Prohibited Acts, enumerates the acts that violate TSCA. It says, somewhat obviously, that a violation of any reporting obligation, any test rule, or any other requirement of 4 or 5 is a violation. Similarly, it is a TSCA violation to fail to maintain required records or allow the EPA to inspect a facility. It adds a very critical dimension to the list of violations by stating that using a substance that was manufactured in violation of TSCA is itself a violation of TSCA. The most significant language is that it shall be unlawful for any person to. .. (2) use for commercial purposes a chemical substance or mixture which such person knew or had reason to know was manufactured, processed, or distributed in commerce in violation of the 5 and premanufacture notification (PMN) rules, a ban or restriction under TSCA 6 or 7, or a rule or order under those sections. 

The notification the employer sends the Area Director is referred to as abatement certification. For Other-Than-Serious violations, this may be a signed letter identifying the inspection number and the citation item number and noting that you corrected the violation by the date specified on the citation. For more severe violations (such as Serious, Willful, Repeat, or Failure-to-Abate), abatement certification requires more detailed proof... 

Notification of Corrective Action - For each violation which you do not contest, you are required by 29 CFR 1903.19 to submit an Abatement Certification to the Area Director of the OSHA office issuing the citation and identified above. The certification must be sent by you within 10 calendar days of the abatement date indicated on the citation. For Willful and Repeat violations, documents (examples photos, copies of receipts, training records, etc.) demonstrating that abatement is complete must accompany the certification. Where the citation is classified as Serious and the citations states that abatement documentation is required, documents such as those described above are required to be submitted along vrith the abatement certificate. If the citation indicates that the violation was corrected during the inspection, no abatement certification is required for that item. 

Not later than 90 days after receiving the initial notification of the intent to convert temporarily a production facility, the inspectors shall have the right to visit the facility to familiarize themselves with the proposed temporary conversion and to study possible inspection measures that will be required during the conversion. 

This Agreement shall enter into force upon approval by the Executive Council and signature by the two Parties. If the inspected State Party has additional internal requirements, it shall so notify the OPCW in writing by the date of signature. In such cases, this Agreement shall enter into force on the date that the inspected State Party gives the OPCW written notification that its internal requirements for entry into force have been met. 

EPA agrees with those commenters who believe that prior notification for every project is simply too burdensome for the regulated community and for the agency. If the streamlined, telephone-based system recommended by some of the commenters were implemented, it would reduce the initial burden on the renovation firms. However, EPA would still have to process millions of such notifications annually, and the collective bnrden on renovation firms and the government would be considerable. Rather than require millions of notifications annually, the great majority of which would never be reviewed, EPA prefers to nse other methods for targeting renovation projects for inspections. 

For practices, the Regulatory Authority shall establish a programme of control for sources through notification, registration and/or licensing conduct an inspection programme to assess protection and safety and take enforcement action in the event of non-compliance with requirements. 

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