Planning Tips for Environmental Audits
Kornreich, Lawrence D., Occupational Hazards
ENVIRONMENTAL AUDITS have become quite popular with American companies. So popular, in fact, that it is hard to get agreement today on what the term "environmental audit" means. It is used to describe a range of investigations from detailed, structured compliance reviews, to due-diligence assessments for property transfers. One thing you can get agreement on: a company with a well-conceived audit program has a better chance of surviving a battle in the courts, or with a regulatory agency, than one without such a program.
As the field of environmental auditing has grown over the past 20 years, there have been major changes in the scope of the audits, and in the approaches that companies have taken in developing and implementing their programs. Changes will undoubtedly continue to occur, especially because of the impact that European and international standards and regulations have had on the practices of U.S. companies.
As you review your audit program, or contemplate implementing one, there are some basic do's and don'ts that are worth keeping in mind.
First, the things you should do:
Commit to corrective action. Perhaps the most important part of the environmental audit is the action that must be taken to correct any defects or deficiencies that are found. If your company is not firmly committed to corrective action, the audit program may expose problems that can prove to be an embarrassment, or worse: a civil or criminal action by a regulatory agency, or a lawsuit. Be sure to make the corrective action plan and follow-up an integral part of the audit program.
Set specific goals. Decide whether the audit will be limited to determining your company's regulatory compliance status, or will be more comprehensive. Should the audit measure the effectiveness of existing environmental programs? Should participation in the audit program serve as a training exercise, and thereby increase the environmental awareness and knowledge of both environmental coordinators and managers? Be sure to use your management's expectations as a guide to setting the proper goals for your company's program.
Encourage in-house participation. It is best when your company's own personnel participate in the audit. An expert leader should guide the team, and no one should audit his/her own facility. However, people from within the organization can sharpen their environmental management skills and publicize management's concern for environmental issues by participating on audit teams. (Your company may not be able to follow this recommendation because of limited staff, or too few sites.)
Define the scope. At the very beginning, agree on what will be investigated. Will audits include areas beyond the environment, such as health and safety? Will audits include the full range of environmental issues: air, water, waste, pollution, etc.? How much time will be available for the audit? Will the auditors also act as "helpers," by providing assistance to on-site management in solving problems that they find? Decide whether or not to initially use an outside consultant as the audit team leader, to help establish impartiality and lend credibility to the program.
Establish an adequate budget. Make sure that once the commitment is made to implement an audit program, sufficient funds are provided for its development and full implementation. This should include repeat audit cycles.
Document fully and accurately. A key to the acceptance of, and the respect for, an audit is complete and full documentation of all work done by the audit team.
Update the program periodically. …