Two EPA representatives inspected Alaska Pacific Seafood Division on September 14, 2004. Based upon this inspection, EPA believes Alaska Pacific is in violation of the following risk management program elements:
Management, Hazard Assessment, Compliance audits, and Risk Management Plan.
Specifically, at the time of inspection, Alaska Pacific did not have a management system in place to oversee the implementation of the Risk Management Program (? 68.15(a)). Alaska Pacific did not have the documentation demonstrating that the off-site consequence analyses was updated at least every five years including using the most current census. Alaska Pacific did not document that the identified audit findings had been corrected. Alaska Pacific did not have documentation demonstrating that they reviewed, fully updated, and submitted a complete copy of a RMP to the RMP Reporting Center by their original anniversary date of June 21, 2004.