Report Writing

Overview

Know your audience and purpose

What about “areas of concern”?

Details!

Questions?

Report Writing

Setting the Stage

Be Prepared

Be Observant

Be Professional

Be Safe

Ask questions

Take good notes

Take lots of photos

Audience Purpose

The operator Educate, inform, improve, prevent

The public Documentation, assurance…

Your colleagues Back-up…

Your future self Documentation, planning…

CalRecycle Meeting cert requirements, 18-month prep…

Other agencies Referrals, coordination…

Future enforcement actions Support…

Report Writing

What if there are no violations or AOC’s?

Weather and other site conditions

Who else was present

Location of working face and other activities

Records reviewed

Provide constructive criticism

Expectations and upcoming due dates

Report Writing

What is an “Area of Concern”?

“A determination made during an inspection or

other site visit, where in the judgment of the

inspector conditions and/or records and/or

operations at a site are of such a state as to be

approaching non-compliance. The conditions

do not yet warrant a violation, but are brought

to the operator/owners attention to indicate

that further lack of compliance could be called

a violation at subsequent inspections.”- SWIS Data Dictionary https://www2.calrecycle.ca.gov/SWFacilities/Directory/Definitions/

Area of Concern

Although available for use on inspection

reports, the term "area of concern" is not

defined or referenced in regulations.

This lack of definition/guidance has lead to a

variety of uses for the "area of concern" box by

both State and LEA inspectors.

A quick survey of actual LEA inspection reports

identified several different categories of uses.

Area of Concern

A Field Guide to Types of AOCs

Not a V yet, but likely if preventative steps not taken

Isolated incident (in time or space)

Almost or barely a violation

Flag for follow-up/further research/wait-n-see

Gray area/subjective standard

Referral of a standard not in the LEA's jurisdiction (RWQCB, DTSC, or CalOSHA standard)

Area of Concern

A Field Guide to Types of AOCs

First offence/warning/guidance

Violation, but fixed during inspection

Not a violation if fixed by next inspection

Benefit of the doubt/good faith effort

Extenuating circumstances

These AOC examples are not necessarily appropriate

and/or consistent with the “working definition” in SWIS.

Area of Concern

Describe

Explain

Direct

Limit

Exit strategy

Follow-up

• Describe observations in detail to help the

operator prevent a future violation.

• Explain (for CalRecycle and your future self)

why it’s not being cited as a violation and

what circumstances were taken in to

consideration.

• Provide some direction and expectations to

operator.

• Helpful to give a time limit to address the

concern.

• Have an exit strategy so you don’t end up

with the same AOC many-months in a row.

• Follow up in your next inspection report.

Area of Concern

Examples From Actual Inspection Reports Erosion Control: Erosion gullies, but no waste exposed.

Litter: Blowing paper and plastic, but none off-site.

Gas Control: Gas below 5%, but above 2.5%.

Training: Staff adequately trained, but not following training.

All records available for review, but some dates missing.

Observed truck drivers not wearing hard hat when out of vehicle.

Site Security: Small holes in fence. Fix by next inspection.

Chipping and Grinding Operation: Temp barely over 122 degrees for the first time.

The posted phone number is no longer in service. Please provide a current phone number on the entrance sign.

Area of Concern

Think about how you want to organize your report.

Chronologically from beginning to end, from arrival to

exit interview.

A bulleted list of organized by topic.

Landfill zones: working face, office, top deck, side slopes,

site perimeter, recycling and salvaging, roads, etc.)

Include some background and tell a story.

Develop your own style or template.

Violations and AOCs

Quote the regulations, RFI section, or permit condition cited

Include the operator’s side of the story, if appropriate

Include some background and context

Be as specific as possible (the working face was 200 x 300 ft.)

Avoid non-specific language (the working face was “huge”)

Avoid using loaded, judgmental, or accusatory language

Sometimes helpful to send via Notice of Violation/cover letter

Follow up in your next inspection report

Violations and AOCs

Whenever possible, assertions and findings should be supported

by your personal observation, a statement by the LEA, operator,

or landfill personnel, or a quote from the operating document,

permit or other correspondence:

"I observed..."

"The operator stated,"

"According to the LEA, "

Page 9 of the RDSI states, "

“Conditions 17.d of the permit specifies…”

Violations and AOCs

Whenever possible, assertions and findings should be supported

by your personal observation, a statement by the LEA, operator,

or landfill personnel, or a quote from the operating document,

permit or other correspondence:

"I observed..."

"The operator stated,"

"According to the LEA, "

Page 9 of the RDSI states, "

“Conditions 17.d of the permit specifies…”

Violations and AOCs

Report Writing