How to Conduct Your Own Environmental Audits By Norman S. Wei. To audit or not to audit that is the question facing many environmental managers.

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1 How to Conduct Your Own Environmental Audits By Norman S. Wei To audit or not to audit that is the question facing many environmental managers. This article describes two types of environmental audits and should do one and how you should do it. Never perform an environmental audit unless you know you have the management commitment and financial resources to correct any problems that may come out of the audit! What are environmental audits? There are basically two types of environmental audits. If done they can be very beneficial tools for environmental managers to environmental regulations. Audits can be used as a "self-check" or self-evaluation to help you determine two things: Your environmental compliance Status - This is simply a check on how well you are complying with federal, state and local requirements. It is nothing more than a snap shot of where you stand the day you perform the audit. You are basically asking yourself the question: Is anything wrong here today? This is an environmental compliance audit. Your Environmental Management Systems This tell you a lot about whether your company has the management infrastructure to come into compliance and stay in compliance. You are 1 of 10

2 asking the question: What happens when something goes wrong tomorrow? This is an environmental management audit. Two different concepts and two different approaches. What to look for in a compliance audit When you are doing a compliance audit, you are looking for "tangible things". You are looking for physical evidence of noncompliance. For example, you may be looking for things such as: Discoloration of soil or dead vegetation at your facility as evidence of chemicals spills. General conditions of housekeeping Conditions of hazardous waste containers. Are the containers severely dented? Do they show signs of leakages? The presence of clearly marked labels on hazardous waste containers. The presence of secondary containment in areas where oil or wastes are stored. The presence of clearly marked accumulation date on the Hazardous Waste label on the container, etc. Evidence of weekly inspection of the hazardous waste storage area. You may also be reviewing records such as: Hazardous waste manifests. Has the plant received the signed copy from the Treatment Storage and Disposal Facility? Environmental permits. What are the limits on the wastewater discharge permits and air permits? 2 of 10

3 Waste water discharge monitoring reports. Have there been violations of the effluent limits? Storm Water Pollution Prevention Plan and/or Spill Prevention Control and Countermeasures (SPCC) Plan. Are these plans up to date? Have inspections been done according to the plan and have they been documented? Hazardous Waste Contingency plan. Does the plant have an up-to-date hazardous waste contingency plan on site ready for inspection by the agency? Employee training records. Have employees been trained and is the training documented? These are just examples of some of the things that you will be looking for. Most people use a checklist to ensure they don t miss anything out. There are several useful resources available for conducting compliance audits. EPA has published protocols for auditing hazardous waste generators under RCRA. Other protocols are also available for auditing compliance with EPCRA (Community Right to Know), CERCLA (Superfund) and other environmental statutory requirements. Keep in mind that environmental compliance audits do not tell you if the facility will be in compliance the day or week after your audit. It is merely a snap shot of the compliance status on the day the audit is performed. Also remember that every time you walk through the plant, you are (or should be) in effect doing a compliance evaluation in your head. When you see certain situations that are out of compliance, you should sit down with your plant manager or engineer and start the process of correcting the problem. 3 of 10

4 Should you write an audit report? If at all possible, avoid preparing an audit report. And you definitely should not fire off a nasty interoffice memo telling everyone what terrible problems you have discovered in your internal audit. A much better approach to alerting everyone about a recurring non-compliance situation is to issue a reminder memo telling all those involved what needs to be done properly without revealing to the world that you have found these violations. (Note: This advice obviously does not apply if the law requires you to disclose the violations to the agencies. A classic example would be violation of a permit effluent limit.) In short - you want to focus your energy and resources on fixing the problem rather telling the whole world you have a problem. First thing you need to do is to sit down with the plant manager and brief him/her verbally on what you have found and what needs to be done to fix it. If you are from corporate headquarters, your most valuable asset to the plant would be to reassure the plant that you will support the plant in obtaining the needed capital dollars approved by senior management to fix the problem. Always make sure you follow up to see that the problem is fixed. Document what the plant has done to fix the problem. What if you have found a lot of problems during your audit and you know you don t have the money to fix them all. What you need to do here is to prioritize the problems and focus on the most serious ones first and document how they are being addressed. Focus those 4 of 10

5 problems that have the greatest potential for causing harm to the environment and human health. For example, let s say you discover through your audit that the base of an aboveground storage tank holding thousands of gallons of highly toxic chemicals is showing some visible signs of corrosion. You should then focus your resources on getting structural integrity tests done on this tank immediately. Fix it and document it. The worst thing that can happen to you in this example is for you to write an inter-office memo to the plant requesting a structural integrity test and for the plant manager to scribble on the margin that he is not going to do it because there is no budget for it. And two weeks later the tank ruptures and you have a catastrophic event on you hands. It is also a knowing endangerment situation since you and the plant manager both knew about the problem and chose not to fix it. What to Look for in an Environmental Management Audit When you perform an environmental management audit, you are looking at the people involved. You are looking at how the facility personnel managed their operations in order to stay in compliance. For example, you will be looking at the following: Management structure. Who is managing the environmental program at the plant? Accountability. Who are held accountable on environmental issues at the facility? Staffing level/capability. What is the staffing levels at the facility and what training have they received? 5 of 10

6 Response capability. How well does the staff respond to an emergency chemical spill? What kind of responder training have they received? Plant ownership. Does the facility staff have ownership of their prepared environmental plans, such as Spill Prevention and Control Countermeasures, Storm Water Pollution Prevention Plan, RCRA contingency plans, etc.? How well do they know these plans? How much involvement did they have in the preparation of these plans? Relationship with regulatory agencies. How well do the plant personnel especially the plant manager get along with the local regulatory agencies? There are numerous case studies(better known as horror stories) out there on how an antagonistic relationship between a plant manager and the local regulatory agency transformed a minor non-compliance issue into a major multi-million dollar enforcement action. This is perhaps the most critical and revealing component of the management audit. Ask Open-ended Questions Always ask open-ended questions when you perform an environmental management audit. Ask questions that start with who, what, how, when, why, where. Here are several open-ended questions on specific management issues you can ask during your audit: Environmental Policy 6 of 10

7 What kind of environmental policy statement and written procedures for environmental compliance do you have for your personnel? How is this policy communicated to the employees? Who are made aware of it? Organization Who is responsible for the overall implementation of your environmental management system? How are employees' responsibilities for environmental compliance defined in their job descriptions? How does the plant keep in touch with the latest regulatory requirements? If you have multiple plants, how do the facilities communicate with each other? How dependent are the plant personnel on head office and outside consultants for support? What is the working relationship between the facility personnel and the local regulatory agencies? Written Procedures What are the written procedures for employees to use in the event of a chemical spill? What are the internal procedures for making sure that problems identified in any internal audits are corrected in a timely fashion? Training How do you train your workers? 7 of 10

8 What kind of training do the workers receive and how often? Accountability Who are held accountable for the plant s environmental performance? How are they rewarded or reprimanded if they fail to perform? Review How often do you review your environmental management system to make sure it is up to date? Who reviews the environmental management system? At what management level are these reviews performed? By the way, the best way to ask these open-ended questions is in an informal setting. Don t turn an audit interview into an interrogation. You can find out a lot more from people when they are at ease with you. How to sell the audit idea to your senior management There are many benefits in doing regular internal review/audit. Here are some of them you can use to sell the idea to your senior management: You can correct environmental problems before they become too large or costly to fix. You can identify opportunities for cost savings through waste minimization, recycling and source reduction. You can minimize your environmental liability by reducing incidents of chemical spills You can reduce environmental liability insurance costs. 8 of 10

9 You can focus employee attention on environmental issues. Your customers can recognize you company as an environmentally responsible organization. You can also improve your corporate image and investors relations by going beyond what is required by regulations. Final Words of Caution Make sure you do environmental audits for the right reasons. Don t do them because you know how to protect your audit results from the agencies. It is certainly a good idea to protect your audit results through the process of attorney/client privileges. However, it is not a good idea to spend your entire audit budget in hiring outside counsel and consultants in order to protect your audit findings and not have money left over to fix the problems. Keep in mind that only the actual audit reports or communications prepared through the attorney/client privileges process are protected. The underlying facts of the audits are never protected. You need to strike a balance. To sum up: You do audits because you want to correct problems before they become too big and costly to fix. Now that s is a pretty good reason. About the Author Norman Wei is principal of Environmental Management and Training, LLC., a consulting and training company based in Cape Coral, Florida. He conducts environmental compliance seminars throughout the country. Norman has over 40 years of real-world environmental experience. He was the senior corporate 9 of 10

10 environmental manager for a Fortune 500 company with numerous facilities worldwide. He can be reached at His address is norman@proactenv.com. Visit his company website at 10 of 10