Published in the August 2020 Focus on the Environment Newsletter.
In our July 2020 newsletter, we introduced Ohio EPA’s pilot program on the use of virtual site visits (VSVs) for select categories of inspections. Recently, I made the trip to a client’s facility and provided assistance conducting a VSV with Ohio EPA during a RCRA Post-Closure inspection. Regardless of the type of VSV inspection, below are some helpful tips to prepare for and conduct the VSV.
Ohio EPA will contact the facility regarding their intent to perform a VSV and schedule a date/time for a trial run to test the audio and video equipment/software. Ohio EPA uses the Microsoft Teams platform, so it is recommended you become familiar with its operation and test it ahead of the trial run. During the trial run, the audio and video will be tested, however, there will not be a need to walk the facility. Near the conclusion of the trial run, a mutually agreeable date/time for the actual VSV will be determined. If not previously discussed, it is recommended that the facility ask the agency if there are specific areas of interest Ohio EPA was planning to cover during the VSV.
Following the trial test and prior to the VSV, it is recommended that the facility perform a mock VSV with other facility members observing remotely. This will allow the person who is conducting the walk-through to develop an efficient travel path, identify any potential issues that need corrected, and ensure a strong audio/video signal throughout the walk. If an area of the facility is encountered with a weak signal, you will have time to troubleshoot options for improving the signal. At worst case, you will be able to provide Ohio EPA with a heads-up that certain portions of the VSV may lose audio and/or video. A weak signal will freeze the video before the audio drops off. If you find that the video freezes and remains frozen after passing through the area with the weak signal, manually turn off your camera feed (while remaining connected via audio) and then turn it back on to re-establish video.
At the start of the VSV, plan to spend a few minutes in an office area to re-iterate the agency’s areas of interest and prioritize certain items. The VSV is typically scheduled for two hours and the agency expectation is to not run beyond this time to avoid scheduling conflicts with both the agency and facility. If document review is part of the inspection, the agency will typically ask that certain documents are provided ahead of or after the VSV so as to not spend time searching or reviewing documents while live streaming.
When conducting the VSV, it is recommended a group of at least two facility personnel perform the walk-over. One person would be in charge of operating the video stream and would perform most of the talking. The second person would lead the route and take notes. The person operating the video feed may be somewhat distracted and not fully aware of their surroundings, therefore the second person also serves as a safety lookout.
There is typically a few second delay from saying something to when it is heard by others that are logged into the VSV. Therefore, if two or more facility personnel are performing the walk-over and each is using their own device for audio, a few feet of distance should be maintained between them to avoid echo or difficulty hearing. Only one person needs to operate a video feed, the other person on the walk-over should have only audio feed active. Because Microsoft Teams allows use of an internet link for audio/video or a phone number for audio only, it is recommended that the facility person who is not leading the video stream use the phone number. Often, the phone signal may be stronger than the internet link for audio/video so if the person who operates the video feed happens to completely lose signal, the other person can notify the agency of the temporary issue.
Some devices have longer battery life than others. It is recommended to have a full charge on the device that will run the video feed before the VSV begins and to also bring a backup battery pack.
Many facilities have proprietary operations. Although the agency will typically provide copies of any screenshots they take during the VSV, it is recommended that the operator turn off the video feed or point the camera to the ground between locations. Not only will this approach prevent potential for photographing proprietary operations, but it will also keep the VSV focused on the intended items, avoid straying from the planned walking path, and allow the facility personnel to be more alert on their surroundings when walking.
Many facilities are loud and may require hearing protection. As such, it is recommended that ear buds (wireless or wired) be used for the audio interface rather than a speaker. Although ear buds do not provide the same hearing protection as ear plugs, you may be able to convince your safety department to allow use of the ear buds in place of the ear plugs during the VSV. Consideration of the time spent at a noisy area and the protection provided by the ear buds should be considered. If additional hearing protection is unavoidable, the use of ear buds under muffs may be possible. Do not hesitate to discuss this issue with Ohio EPA in the trial run call.
Following the walk-over portion of the VSV, Ohio EPA will likely review their inspection checklist while the audio/video stream is still live. If not, the facility personnel should request that it is reviewed prior to concluding the VSV. By reviewing the checklist together, any potential misinterpretations or issues may be quickly clarified or addressed.
The above tips should help for a smooth and productive VSV. A follow up letter on the VSV will be provided by Ohio EPA, which will include the completed checklist, any screenshots taken, and outcome. Ideally, this letter is provided within 30 days of the VSV. If you don’t receive the letter within this timeframe, it is recommended to inquire on its status.
Nick M. Petruzzi, PE, CPG is a Principal Engineer at Cox Colvin & Associates, Inc. Mr. Petruzzi holds degrees in both geology and environmental engineering. He has been involved with numerous projects that have required the evaluation, design, construction, and operation of both established and innovative remedial alternatives for the treatment and disposal of contaminated soil and groundwater at industrial facilities. He also provides management and technical services on projects that deal with hydrogeologic investigation as well as hazardous waste, NPDES, and air permits. Mr. Petruzzi was a contributing author and instructor for the Interstate Technology and Regulatory Council (ITRC) Green and Sustainable Remediation (GSR) team, is a registered Professional Engineer in the State of Ohio, Kentucky, and Pennsylvania, and is a Certified Professional Geologist.