EHS Audit Overview

EHS Management Strategies
Environmental Compliance
Solid and Hazardous
Waste Management
Waste Minimization and
Pollution Prevention
Water Pollution Control
Spill Prevention and
Control
Air Pollution Control
Asbestos Management
Toxic Substances
Management
PCB Management
Emergency Planning
Hazardous Materials
Transportation
Underground Storage
Tanks
Pesticide Management

Proactive Management of
Environmental Compliance
Proactive management
 “What are we doing wrong?
How can we do things better?”
 “Our fancy schmancy EMS is
developed and implemented,
and auditing is just one part of
continuous improvement.”
Plan
Check
Do
Feedback
Environmental Auditing

What is an Environmental Audit
An objective, systematic examination of facilities, processes,
procedures and practices to verify whether they comply with legal
requirements, internal policies and accepted practices.
Objectives
 To find problems
 To report them expeditiously (if required)
 To resolve audit findings in a timely fashion by correcting their root
causes
“Audit” vs “Review”

Other Drivers for Environmental
Audits
EPA’s audit policy/state privilege laws
 “We may not be penalized (as much) for identifying/disclosing our
problems as we would if the regulators found them before we did.”
Federal enforcement policies
 “Because of our poor environmental performance, we are under an
agreed order to implement an EMS, including audits. EPA is
tracking our every step.”
Fine prevention $$$$$$
 “Oh fudge, the regulators are coming! Give us an audit QUICK, so
we can find/fix our problems before they do it for us!”

Environmental Audit Process
Opening meeting/tour
Understanding EMS
Gathering evidence
(interviews, records
review, inspection)
Summarizing findings
Closing meeting
On-Site
Visit
Corrective
Action
Planned fixes
Responsibility
assignment
Timetable
Documenting closure
of findings
Planning
Stage
Protocol
development
Logistics planning
Pre-review
questionnaire
Reporting
Exception-based,
factual statements
Root cause assessment
Suggested process
improvements
Identification of Best
Management Practices

Making the Audit Process Work
You need the right team.
You need the right tools.
The logistics are a hassle.
The findings are sensitive (in come the
attorneys).
Companies who commit themselves to audits
must be ready to commit themselves to
implementing effective corrective actions.

Sample Audit Finding
Exception-based
compliance finding
 No documentation was available
of notification to the local
emergency planning commission
(LEPC), SERC, and local fire
department of hazardous or
extremely hazardous substances
present at the facility at any one
time in quantities above their
corresponding thresholds. In
addition, no documentation of Tier
II reporting was available.
Action item
 .Action: Verify the facility does not
increase the use of potable or
process water or, in any way, dilute
an effluent to meet permit
limitations.
 Requirement: “The permittee shall not
increase the use of potable or
process water or, in any way,
attempt to dilute an effluent as a
partial or complete substitute for
adequate treatment to achieve
compliance with the limitations
contained in this permit” (Permit
No. 22, Section A.10).

Sample Root Causes of Audit
Findings
16
33
8
9
Procedures
Equip./Facility Design
Management
Document Mgmt.
Unaware of Applicability
of Regulation
39 Total Findings

Sample Corrective Action Plan
Finding
Root
Cause
Corrective
Action Plan
Person
Responsible
Due
Date Status
Emergency Planning and Release Reporting (CERCLA/EPCRA/SARA)
SARA 311: No documentation
was available of notifications
to the local/state emergency
planning/response
commissions (LEPC/SERC)
and local fire department of
hazardous or extremely
hazardous substances
present at the facility in
quantities above their cor
Unaware of
Applicability
of
Regulation;
Procedure
Not Written
or
Implemente
d
Submit appropriate
notifications to the LEPC,
SERC, and local fire
department.
Mike Stevens;
ThermoRetec to
support
Q4
1999
Completed
1/10/00
SARA 312: No documentation
of Tier II Hazardous Chemical
Inventory reporting was
available.
Unaware of
Applicability
of
Regulation;
Procedure
Not Written
or
Implemente
d
Submit missing Tier II
Hazardous Chemical
Inventory report(s).
Mike Stevens;
ThermoRetec to
support
Q4
1999
Completed
1/10/00
These are short-term
solutions only. Long-
term solutions need to
address root cause.

Types of Environmental Audits
Multimedia compliance
audits
 Do the facility’s practices and
records demonstrate
compliance with regulatory and
policy requirements?
 Is there evidence of compliance
problems? If so, what is the root
cause?
EMS audits
 If the system is followed
exactly, will all regulatory/policy
requirements be met?
 Is the system being used
appropriately by employees?
 Are there ways to
improve/update the system?
Compliance-based EMS Assessments
 All of the above. This is the best way to find problems AND reasons behind
them.

Summary of Our Services
Support for our clients’ audit programs
 Team members on their audits
 EMIS tools to track scheduling logistics, audit findings, corrective
actions
Reviews that are completely external
Audits combined with EMS/EMIS
implementation
Get certified in 120 days!!!

EHS Management Strategies, LLC
Greenhouse Gas Survey
Liability Review and SOX Reporting
Management System Auditing / Training
 ISO 14001, TS 169494, OHSAS 18001, ISO 9001, ISO 2200
SPCC / SWPPP Updates
RCRA / DOT Training
Air & Water Reporting / Permitting
OHSA Auditing & Program Development
Behavior Based Safety Programs

EHS Management Strategies, LLC
James Charles, PE
Senior Consultant
James.Charles@iso14001-training.com
(616) 666-5490
WWW.ISO14001-Training.com

EHS Audit Overview

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