Environmental audit

It is a general term that can reflect various evaluations intended to quantify environmental performance/compliance. There are generally two different types of environmental audits: compliance audits and management systems audits. Compliance audits tend to be the primary type. By definition, environmental audit is a systematic, documented, periodic and objective process in assessing an organizations activities and services in relation to: Assessing compliance with relevant statutory and internal requirements Facilitating management control of environmental practices Promoting good environmental management Maintaining credibility with the public Raising staff awareness and enforcing commitment to departmental environmental policy Exploring improvement opportunities Establishing the performance baseline for developing an Environmental Management System (EMS). Conducting an environmental audit is no longer an option but a sound precaution and a proactive measure in todays heavily regulated environment. Indeed, evidence suggests that EA has a valuable role to play, encouraging systematic incorporation of environmental perspectives into many aspects of an organisations overall operation, helping to trigger new awareness and new priorities in policies and practices.

Objectives of Environmental Audit

The overall objective of environmental audit is to help safeguard the environment and minimize risks to human health. Clearly, auditing alone will not achieve this goal; it is a management tool. The key objectives of an environmental audit therefore are to:

determine
performing

how well the environmental management systems and equipment are

verify compliance with the relevant national, local or other laws and regulations minimize human exposure to risks from environment, health and safety problems.

Environmental Compliance Audits

As the name implies, these audits are intended to review the company's legal compliance status. Compliance audits generally begin with determining the applicable compliance requirements against which the operations will be assessed. This tends to include national regulations, state regulations, permits and local codes. In some cases, it may also include requirements within legal settlements. Compliance audits may be multimedia or programmatic. Multimedia audits involve identifying and auditing all environmental media (air, water, waste, etc) that apply to the operation/company. Programmatic audits are limited in scope to pre-identified regulatory areas, such as air. Audits are also focused on operational aspects of a company/site, rather than the contamination status of the real property.

Environment Management System Audit :ISO 14001

ISO 14001 is a voluntary international standard for environmental management systems ("EMS"). ISO 14001:2004 provides the requirements for an EMS and ISO 14004:2004 gives general EMS guidelines. An EMS meeting the requirements of ISO 14001:2004 is a management tool enabling an organization of any size or type to: (1) identify and control the environmental impact of its activities, products or services; (2) improve its environmental performance continually, and (3) implement a systematic approach to setting environmental objectives and targets, to achieving these and to demonstrating that they have been achieved. The goal of ISO 14001 implementation is to obtain certification. This indicates that the environmental procedures, systems and documentation standards conform to the established ISO14001 standard. A common misconception is that ISO certification directly reflects legal compliance. Certification under ISO 14001 does not directly reflect compliance with any legal requirements.

Scope of the Audit

As the prime objective of audits is to test the adequacy of existing management systems, they fulfill a fundamentally different role from the monitoring of environmental performance. Audits can address one topic, or a whole range of issues. The greater the scope of the audit, the greater will be the size of the audit team, the time spent onsite and the depth of investigation. Where international audits need to be carried out by a central

team, there can be good reasons for covering more than one area while onsite to minimize costs. In addition, the scope of an audit can vary from simple compliance testing to a more rigorous examination, depending on the perceived needs of the management. The technique is applied not only to operational environmental, health and safety management, but increasingly also to product safety and product quality management, and to areas such as loss prevention. If the intention of auditing is to help ensure that these broad areas are managed properly, then all of these individual topics must be reviewed. Items which may be addressed in audits, including environment, health, safety and product safety are shown in table 1. Although some companies have a regular (often annual) audit cycle, audits are primarily determined by need and priority. Thus not all facilities or aspects of a company will be assessed at the same frequency or to the same extent.

Table 1.

Scope of environmental audit Occupational Health Employee exposure to air contaminants Exposure to physical agents, e.g., noise, radiation, heat Measurements of employee exposure Exposure records Customer information on product handling and quality Regulatory compliance Labeling Specifications for purchased materials/products/packagin g Materials safety data Vendor qualification program QA testing and inspections Record keeping Product literature Process control Product Safety Product safety program Product quality control Product packaging, storage and shipping Product recall/withdrawal procedures

Environmental Safety Site history Safety policy/procedures Process/materials Accident reporting Storage of materials above ground Permit to work systems below ground Air emissions Accident recording Accident investigation

Special procedures for confined space entry, work Ventilation/engineering controls on electrical equipment, Water discharges breaking into pipelines, etc. Personal protective equipment Liquid/hazardous Emergency response Information and training on wastes health hazards Fire fighting Asbestos Medical surveillance program Job safety analysis Waste disposal Hearing conservation Safety training onsite First aid Safety communication/promotion offsite Regulatory requirements Housekeeping Oil/chemical spill prevention Regulatory compliance Permits/licenses

Table .2.

Basic steps in environmental auditing

Audit processes, methods and tools

The term "protocol" means the checklist used by environmental auditors as the guide for conducting the audit activities. Current methodology and technology support many versions of computer-based protocols that attempt to simplify the audit process by converting regulatory requirements into questions with "yes", "no" and "not applicable" check boxes. Many companies and auditors find these useful and there are several such protocol systems commercially available. With the advancement in technology, laptop, computers, portable printers, CD/DVDs, the internet, email and wireless internet access have all been used to improve audits, increase/improve auditor access to regulatory information and create audit reports on-site.

Related types of assessments

Phase I Environmental Site Assessments ("ESA") are generally done in relation to mergers, acquisitions or financing activities. The intent of ESAs is to identify potential sources/existence of property contamination for purposes of clean up costs/liability under the law. ESA's rarely contain a compliance audit component and should not be confused with audits.

Planning an Environmental Audit

Any premises that wish to conduct an environmental audit must have a clear idea of the objectives of the exercise and the steps required to achieve it. Before commencing an environmental audit, the following requirements must be fulfilled: 1. Commitment

Obtain commitment management Communicate commitment to personnel at all levels

2. Define audit scope and audit sites To include: Audit site and boundary Audit objective(s) Areas of audit

Audit objectives typically entail:

Verification of legislative and regulatory compliance Assessment of internal policy and procedural conformance Establishment of current practice status Identification of improvement opportunities

Areas of audit normally encompass: Material management, savings and alternatives Energy management and savings Water management and economy of use Waste generation, management and disposal Noise reduction, evaluation and control (internal and external) Air emissions and indoor air quality Environmental emergency prevention and preparedness Transportation and travelling practices Staff awareness, participation and training in environmental issues Environmental information publicity Public enquiry and complaints response Environmental management system set up, suitability and performance

Conducting an Environmental Audit

An environmental audit is typically undertaken in three phases: Pre-audit On-site audit Post-audit

A. Pre-audit activities
Objectives To develop an audit plan for the on-site activities To make the necessary preparation and arrangements for the on-site audit

Actions 1. Develop an audit plan The Audit Plan should address: Where: audit site & boundary with overview What: scope & objectives How: site personnel interview, site inspection, audit protocols; site logistics and administrative arrangement Who: audit team and site facilitation arrangement When: audit schedule and milestones

The Audit Team is subsequently to: Seek agreement from management on audit plan Establish the reporting structure

B. On-site audit activities Objectives

The on-site audit objectives should reflect those of the environmental audit, which are: Verification of legislative and regulatory compliance Assessment of internal policy and procedural conformance Establishment of current practice status Identification of improvement opportunities

Actions 1. Operations meeting

Conduct on-site audit Opening Meeting with manager and site personnel to: Introduce audit team members Present audit scope and objectives Outline the audit approach and methodology Address questions or concerns of site personnel Rally staff support and assistance

2. Document review
Audit Team member to undertake a review of relevant document such as: Management policy Management system documentation Operational procedures Records (utility, inventory, monitoring, calibration, trans - portation, training etc.) Previous audit reports Green management team meeting minutes Green suggestions

In particular, to evaluate whether the records are: Current Properly completed Signed and dated Consistent Meet relevant requirements

C. Post audit activities Objectives To produce an Audit Report with audit findings and recommendations To contribute towards formulation of an Action Plan for continual performance improvement

Actions
1. Collate information and follow up outstanding issue Information to be organised should include: Completed pre-audit questionnaire, operational document checklists Completed on-site survey questionnaires, on-site audit protocols All relevant correspondence, memoranda, reports, diagrams and drawings Copies of records, photographs, and other information collected during the site visit Detailed inspection and interview notes and summaries

Benefits of Environmental Auditing

If environmental auditing is implemented in a constructive way there are many benefits to be derived from the process. The auditing approach described in this paper will help to: safeguard the environment verify compliance with local and national laws indicate current or potential future problems that need to be addressed assess training programs and provide data to assist in training enable companies to build on good environmental performance, give credit where appropriate and highlight deficiencies identify potential cost savings, such as from waste minimization assist the exchange and comparison of information between different plants or subsidiary companies demonstrate company commitment to environmental protection to employees, the public and the authorities.

Trends/future developments
Audit programs are becoming a standard environmental management tool and pressures for the disclosure of audit results are increasing. The utility of environmental audits vary from organisation to organisation. It is likely that audits will be used increasingly to:

provide baseline information to enable organisations to evaluate and manage environmental change, threat and risk; form the basis for initiating and monitoring the performance of Environmental Management Systems; contribute to environmental management approaches which become integrated with environmental impact assessment and the management of predicted impacts, mitigation and monitoring measures; support the implementation and management of integrated pollution control procedures tackle external off-site impacts which consider the broader environmental footprint of an organisation's activities; and pass environmentally responsible approaches down the supply chain.

Environmental audits have traditionally dealt with the environmental effects of industrial processes and, to a lesser extent, with resource consumption. Guided by the legislation and compliance procedures, the environment has usually been considered in terms of air land and water. Generic approaches could contribute to the development of conservation management plans.