You’re scheduled to have an environmental, health and safety audit at your facility next quarter. You want the results to be perfect. The prospects add an additional layer of stress to your work day. How will you ever survive?
Here are 6 pointers to ensure the audit is successful.
- Know Why you are doing the audit. And the answer is NOT “to show that you are in compliance.” Audits are an opportunity to bring fresh eyes to your operation, identify gaps in processes or recordkeeping, to meet management systems requirements, or to meet corporate requirements. Keep in mind that it is better to find a gap now (and fix it) than to have an agency inspector find it.
- Have a Plan. Before the audit is conducted, identify and communicate the scope of the audit (e.g., will it just be waste programs, or will it focus on employee safety); determine the best timing (e.g., duration of the auditor site visit, avoid busy seasons); understand desired deliverables (e.g., written findings, verbal report); decide if it will be conducted under attorney-client privilege; identify your level of risk (e.g., monetary limits, best management practices).
- Bring in a good team. Whether the auditors are from an outside firm or internal resources, ensure that they have the appropriate experience and process knowledge. Experienced auditors are trained to move the audit along smoothly. They can help you plan the audit so that you obtain the desired results.
- Expect findings. An audit is a snap shot in time and it is likely that there is one drum in the facility that is not labeled. And of course, the auditor will find that one! Remember that every auditor has different strengths and weaknesses. They are brought in to use a fine-toothed comb. And, don’t expect the auditor to have the same focus as your agency inspector.
Agency inspectors are notorious for having pet peeve issues, or they only look at what they have looked at for the past 5 years. Avoid complacency. If a new inspector is assigned to your facility, he or she may have different pet peeves or different focus.
- Close gaps immediately. As I mentioned, there will be findings. The point is to address them as soon as possible. Fix them during the audit if possible. If the solution is a capital expense situation, then work with management to set a schedule and begin working on it. Identify if there are any interim steps that can be taken immediately. Having documented compliance issues without corrective action is treacherous.
- Plan ahead how you will respond if a finding warrants notifying an agency about non-compliance. If a major non-compliance is identified, your company may decide that the situation must be reported to the agency. Examples may include, a release is discovered or a process has been operating without a permit. Most states have an “audit policy” or a self- disclosure policy where enforcement leniency is provided if the company self-discloses non- compliance situations. The leniency provided may be in the form of reduced fines or eliminate criminal implications. However, each policy has a specific procedure and usually a limited timeframe in which to notify.
Keep in mind that some certified professionals may have an ethical obligation to ensure that these types of non-compliance situations are reported.
Having a workable plan and a realistic attitude toward EHS compliance audits will help your team get beyond the stress of the audit and focus on corrective actions.
If you would like more information about conducting EHS compliance audits or developing an effective and defensible EHS program, please contact us.
Internal vs Outside Auditors
There are pros and cons to using either internal auditors or auditors from an outside organization. Internal auditors know your operation and the business policies of the company. They have shared experience from similar company operations.
- Resources from an outside organization have been given tools and training specific to the audit process, and may have more regulatory experience.
- The Institute of Internal Auditors provides standards and principles that form a framework for EHS audits.
- The Board of Environmental Health & Safety Auditor Certification(R) (BEAC(R)) issues professional certifications related to auditing.