Tennessee’s Department of Environment and Conservation, Division of Solid Waste Management has developed and implemented a statewide uniform inspectors training program that was originally designed as a business process improvement focused on increasing the consistency and transparency of the inspection process across the state. It has now expanded as an outreach offering to the regulated community to increase compliance, build trust and engagement, and promote fairness. Statewide Uniform Inspectors Training (S.U.I.T.) was initiated after the Division Director noticed inconsistencies in the way staff was performing solid waste landfill inspections across the state. The Director’s message to staff was that “we need to call balls and strikes the same in Johnson City and Memphis, and all parts in between.” (Tennessee has eight field offices located from Memphis in West Tennessee to Johnson City in East Tennessee, nearly 500 miles apart.) The Division established a committee composed of representatives from each field office, representatives of the Office of General Counsel, and a technical editor to create the manual and accompanying training course.
Results to Date:
To date, 40 Division staff members (managers, inspectors, and engineers) have had inspector training on Class 1, 2 and 3 landfills. In the training, each violation is covered individually, as are regulatory citations. Photos are included to provide clarity on more complex determinations. Training is conducted annually throughout the field offices. Inspector training provided for the regulated community (Solid Waste Landfill Directors/Operators) began in 2016 for Class 1, 2 and 3 landfills. More than 300 individuals have participated. A nominal fee is charged to attendees to offset the cost of the class and attendees receive landfill operator training certification credit.
As part of S.U.I.T., Division inspectors from various field offices, and the landfill operator, participate in a joint inspection at selected landfills. Each individual fills out an inspection checklist, and upon completion of the inspection, a meeting is held to discuss the findings of each inspector and the landfill operator. The goal is to have very similar findings on the checklist, and for inspectors and operators to find the same violations (if any) and grade them in the same manner. This hands-on aspect to the training fosters open communication with the regulated community about what to expect during inspections and provides guidance regarding the Division’s compliance expectations.
Growth opportunities on the horizon include creating standard training manuals and a companion training module for transfer stations, tire storage facilities, used oil collection, compost facilities, convenience centers, land application, and the more complex arena of hazardous waste landfills.
Ashley A. Holt
Deputy Director of Field Operations, Division of Solid Waste Management
Tennessee Department of Environment and Conservation