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What is an Environmental
Audit
Environmental auditing is a systematic, documented,
periodic and objective process in assessing an organization's
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)
Planning an Environmental Audit
An organization that
wishes 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:
Commitment
- Obtain commitment at the Directorate level
- Communicate commitment to personnel at all levels
Define
the Audit Scope
To include:
- Audit site and boundary
- Audit objectives
- 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
- Air emissions and indoor air quality
- Environmental emergency prevention and preparedness
- 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
Each of these phases comprises a number of clearly
defined Objectives, with each objective to be achieved
through specific Actions, and these actions yielding
results in the form of Outputs at the end of each
phase.
Pre-audit
The pre-audit
phase typically includes defining the purpose of
the audit, roles and responsibilities, and the completion
of a pre-audit questionnaire. Once
these items are addressed, the audit schedule is
confirmed, and the on-site review proceeds.
Onsite
audit
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
Opening Meeting
Conduct
an on-site audit Opening Meeting with 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
- Conduct an initial site tour
Document Review
Audit Team members then review relevant
document such as:
- Management policy
- Management system documentation
- Operational procedures
- Records (utility, inventory, monitoring, calibration,
training etc.)
- Previous audit reports
In particular, to evaluate whether the records
are:
- Current
- Properly completed
- Signed and dated
- Consistent
- Meet relevant requirements
Post audit
The objectives
of the post audit are to produce an Audit Report
with audit findings and recommendations that
Contribute towards formulation of an Action
Plan for continual performance improvement.
Information to be organized 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
Development of the Action Plan
Once the audit
is complete, it is incumbent upon the organization
to develop an action plant that allows for not only
obtaining compliance, but marinating compliance. Upon
endorsement of the Audit Report, an Action Plan with
the appropriate targets and objectives for environmental
improvement may be developed in consultation with
audit site senior management.
An action plan should cover:
- Action objectives
- Specific actions required
- Responsible personnel
- Budget allotted
- Implementation program
To monitor progress of Action Plan implementation,
a status report should be prepared and should include
information on:
- Progress of action(s) undertaken
- Problem(s) encountered when action(s) taken
- Proposed solution(s) and revised timescale for
completion
Review the Action Plan upon completion of Action
Plan implementation. Key points to review include:
- Review results of action plan implementation
- Establish levels of performance improvement achieved
- Address possible need for changes in management
policy, objective(s) and procedure(s)
- Next audit
scope and schedule
EPA
Auditing Policy
The EPA
Audit Policy, formally titled “Incentives
for Self-Policing: Discovery, Disclosure, Correction
and Prevention of Violations,” safeguards
human health and the environment by providing several
major incentives for regulated entities to voluntarily
come into compliance with federal environmental
laws and regulations. To take advantage of these incentives, regulated
entities must voluntarily discover, promptly disclose
to EPA, expeditiously correct, and prevent recurrence
of future environmental violations. Disclosures are
often preceded by consultation between EPA and the
regulated entity, so that they can discuss mutually
acceptable disclosure details, compliance, and audit
schedules can be discussed.
Summary of Incentives: Significant penalty reductions. Civil
penalties under the environmental laws generally have two components, an
amount assessed based upon the severity or “gravity” of the violation,
and the amount of economic benefit a violator received from failing to comply
with the law.
- No gravity-based penalties if all nine of the
Policy’s conditions are met. EPA retains
its discretion to collect any economic benefit
that may have been realized as a result of noncompliance.
- Reduction of gravity-based penalties
by 75% where the disclosing entity meets
all of the Policy’s conditions except detection
of the violation through a systematic discovery
process.
No recommendation for criminal prosecution for entities
that disclose criminal violations if all of the applicable
conditions under the Policy are met. “Systematic
discovery” is not a requirement for eligibility
for this incentive, although the entity must be acting
in good faith and adopt a systematic approach to
preventing recurring violations. Refer to the Audit
Policy for a complete discussion of issues relating
to disclosure of criminal violations.
No routine requests for audit reports would be made.
Conditions for Penalty Mitigation
Entities that satisfy the following conditions are
eligible for Audit Policy benefits. Even if your
entity fails to meet the first condition - systematic
discovery - you can still be eligible for 75% penalty
mitigation, and a recommendation for no criminal
prosecution of the violations against your entity.
- Systematic discovery of the
violation through an environmental audit or the
implementation of a compliance management system.
- Voluntary discovery of the violation
was not detected as a result of a legally required
monitoring, sampling or auditing procedure.
- Prompt disclosure in writing
to EPA within 21 days of discovery or such shorter
time as may be required by law. Discovery occurs
when any officer, director, employee or agent of
the facility has an objectively reasonable basis
for believing that a violation has or may have
occurred.
- Independent discovery and disclosure before
EPA or another regulator would likely have identified
the violation through its own investigation or
based on information provided by a third-party.
- Correction and remediation within
60 calendar days, in most cases, from the date
of discovery.
- Prevent recurrence of the violation.
- Repeat violations are ineligible,
that is, the specific (or closely related) violations
have occurred at the same facility within the past
3 years or those that have occurred as part of
a pattern at multiple facilities owned or operated
by the same entity within the past 5 years; if
the facility has been newly acquired, the existence
of a violation prior to acquisition does not trigger
the repeat violations exclusion.
- Certain types of violations are ineligible such
as those that result in serious actual harm, those
that may have presented an imminent and substantial
endangerment, and those that violate the specific
terms of an administrative or judicial order or
consent agreement.
Cooperation by the disclosing entity
is required. |
