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?
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 For example, if an SPCC plan was not updated in the required 5-year period, the deficiency is an outdated plan, but why did that happen?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].