Category: Auditing

Thoughts on Evaluating the Quality of Environmental Compliance Audits

Thoughts on Evaluating the Quality of Environmental Compliance AuditsWhen audits are initiated in response to an outside requirement to perform an audit, simply obtaining a competent audit at a competitive cost may be the perfect solution. In these cases, audit quality isn’t as much of a concern as clearing the pass-fail bar as efficiently as possible. Of course, the audit must be performed in a professional manner and the results need to be adequately documented in a report. The federal government would call this the “lowest cost, technically acceptable” standard. If this sounds like you, your path forward is fairly clear and you should probably skip over the rest of this post.

For those who actually want an environmental compliance audit for their own — perhaps more nuanced — reasons, pinning down the value of an audit can be more complex. The best starting place is often to define why you want an environmental compliance audit at all. These reasons (or goals) should be documented and discussed with the team that is planning the audit or audit program to be sure everyone agrees on the point of it all (spoiler alert: They probably don’t). Once you have clarified why you want an audit, you might ask yourselves some questions like these examples:

  • Am I completely confident deficiencies identified in our audits are applicable and accurate?
  • I want to be confident we uncover as many of our compliance deficiencies as possible, so does our audit approach provide that level of investigation?
  • Do our audits tell me if our internal training and directives are being implemented fully?
  • Do our auditors have the experience to reveal underlying causes of noncompliance, or are we simply fixing what’s wrong today?
  • Do our audits provide guidance on how to correct compliance deficiencies to our facility personnel?
  • Do our managers and staff believe our audit process is reliable, respectful, and professional?
  • How can I maximize the information transfer (training) our operations managers and facility staff receive during and after our audits?
  • Are written audit results prepared in a way that promotes understanding of requirements, builds confidence in the audit process, and simplifies corrective actions?

Environmental compliance audit programs can offer great benefits, but organizations must consider what they want out of the program and decide what audit approach really offers the best value.

5 Benefits of Conducting a Compliance Audit

5 Benefits of Conducting a Compliance Audit

While most organizations have in-house personnel who manage environmental, health, and safety programs on a day-to-day basis, periodic audits by expert third-party auditors have become indispensable for many organizations. Unlike ongoing compliance management activities, compliance audits are evaluations of an organization, facility, or operation to determine its status with respect to applicable, predetermined audit criteria. The scope and audit criteria can be tailored to each organization’s needs, and related assessments or tasks can be integrated into the audit process to its maximize value.

There are several benefits of hiring an EHS team to evaluate environmental or safety compliance for your organization, including the following:

1. Drive environmental protection and workplace safety. EHS regulations are promulgated to provide environmental and safety protection, so improved compliance helps organizations meet the spirit of those requirements and demonstrate proactive leadership. Credible third-party audits can be used to demonstrate effective EHS management to potential customers, shareholders, and other stakeholders.

2. Document compliance status. Properly performed audits offer managers and leadership an accurate understanding of the entity’s compliance position in near real time, and can resolve uncertainties regarding the applicability or requirements of specific regulations.

3. Identify overlooked compliance deficiencies. Third-party auditors offer a “fresh look” at operations and can often reveal compliance deficiencies and emerging challenges overlooked by on-site EHS professionals focused on program implementation and day-to-day operations.

4. Manage risks. Identifying and addressing EHS regulatory compliance deficiencies reduces the risk of environmental releases, accidents, enforcement actions, and negative press.

5. Improve EHS program performance. In addition to identifying compliance deficiencies, audits can improve overall program effectiveness by identifying emerging regulatory challenges, opportunities for pollution prevention or waste minimization, and programmatic root causes.

At Aarcher Consulting, we are compliance auditing experts with the ability to perform comprehensive environmental and safety audits that go beyond the norm. Our teams consistently deliver accurate and reliable audit results and practical corrective action recommendations, which can be integrated with on-the-spot staff training, management recommendations, root cause analysis, EMS evaluation, pollution prevention opportunity identification, and instant reporting.

For more than 20 years, we have performed hundreds of environmental and safety compliance audits for manufacturers, commercial facilities, and federal agencies in every U.S. state. Based on our experience and expertise, Aarcher has been approved by the U.S. Environmental Protection Agency, Department of Justice, and several states to serve as Third-Party Verifier (TPV)/Third-Party Auditor for organizations working to meet the terms of a consent decree (CD), compliance order, voluntary disclosure agreement, or supplemental environmental projects (SEP).

Contact us for more information on our approach to environmental and safety compliance auditing or to schedule an audit for your facility.

 

Is root cause analysis really worth the effort as part of environmental compliance audits?

Well, we think so. Identifying the same type of compliance deficiency in multiple locations, or during each recurring audit for the same facility, can only get us so far. Assuming the deficiency was corrected following each audit, the problem is re-emerging. Perhaps if we figured out the underlying cause, we could resolve it once and for all. This, of course, is the essence of “root cause” analysis, but does this really add value for environmental audit programs?
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We are believers in the value of root cause analysis as a means of using environmental audit findings to drive real organizational improvements. Over the past 20 years, we have led many environmental compliance audits, participated in a variety of audit programs types, consulted to several corporate audit teams, and observed audit programs as they change and evolve over time. We have experienced audit programs that do not address root causes, audit programs with very complex root cause documentation processes, and those with ineffective root cause procedures. All told, we believe that consideration of root causes is an important opportunity for all audit programs, although the approach must be carefully selected based on the realities of the audited organization and the audit program itself.

You probably already understand the concept of a root cause – the underlying factor(s) that led to the observed condition (the deficiency or audit finding) existing. This is the difference between a cause and a symptom. For example, if an SPCC plan was not updated in the required 5-year period, the deficiency is an outdated plan, but why did that happen? Was funding for a consultant not made available? Were employees recalcitrant, forgetful, or stretched too thin? Is more training or a better system for tracking deadlines required? Are responsibilities clear? The bottom line answer is our root cause.

There is a lot of guidance out there on performing root cause analysis, much of it coming from quality, safety, engineering, and management strategies. But these approaches often must be adapted to be practical for our own organizations and audit programs.

If you would like a free paper on how root causes can play a part in your audit program, along with an overview of common methodologies and some tips for success, email me at Craig Schwartz at [email protected] and I’ll send you a copy.

Craig Schwartz is an environmental management consultant with more than 20 years experience helping clients work toward their environmental compliance, performance, and risk management objectives. He is a Certified Hazardous Materials Manager (CHMM), Certified Professional Environmental Auditor (CPEA), and Certified Environmental Trainer (CET) who serves as both an AARCHER consultant and instructor for the Aarcher Institute of Environmental Training. Craig can be reached at [email protected]