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EHS Compliance Audit Strategies
- 1. 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
- 2. EHS Management Strategies 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
- 3. EHS Management Strategies 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”
- 4. EHS Management Strategies 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!”
- 5. EHS Management Strategies 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
- 6. EHS Management Strategies 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.
- 7. EHS Management Strategies 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).
- 8. EHS Management Strategies 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
- 9. EHS Management Strategies 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.
- 10. EHS Management Strategies 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.
- 11. EHS Management Strategies 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!!!
- 12. 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
- 13. EHS Management Strategies, LLC James Charles, PE Senior Consultant James.Charles@iso14001-training.com (616) 666-5490 WWW.ISO14001-Training.com EHS Management Strategies