California Environmental Reporting System (CERS)

Question: How should I report re-inspections or follow up inspections? How should I report related violations?

Answer: Re-inspections, also called follow up inspections, should be reported to CERS as ‘Other’ inspections. Only the initial inspection should be counted as a ‘Routine’ Inspection.

If violations were observed during the initial routine inspection all subsequent related RTC, corrective and enforcement information should be entered into the routine inspection record.

• Add a statement to the comment field: “Inspection is a follow up to the routine inspection dated xx/xx/xxxx. All violations observed during that inspection were / were not corrected.”
  Each follow up inspection would contain the same statement referring back to the routine inspection.
• Addition of any new observed violations. In this case, the subsequent related information would be entered into this ‘Other’ Inspection. Re-inspections are conducted to confirm that previously observed violations have been corrected and therefore should not be another complete inspection of the regulated facility. However, there are occasions when you will observe new violations in the course of your re-inspection and these do need to be tracked and managed.

California Code of Regulations Title 27 Data Dictionary description for field 907, Inspection type, states, ‘…A routine inspection is a regularly scheduled inspection to evaluate compliance. Does not include follow-up inspections. (emphasis added) Other inspections include complaint investigations, closure, release investigations, tank installation and/or removal oversight, tank cleaning, and follow-up enforcement inspections (emphasis added), or other inspections that may be in addition to a regularly scheduled inspection….’. The CalEPA/CFB Guidance Document for Inspection and Enforcement (April 15, 2008) does not define 're-inspection'. However, the 'Sample Inspection and Enforcement Plan from Sacramento County (Revised Oct 15, 2013) posted to the CalEPA website defines a re-inspection as, '...a field inspection conducted outside the regulatory frequency.' The Water Board's instructions for completing the quarterly report (Report 6) state that '...do not count...corrective action inspections.'