companies today conduct their own environmental audits to monitor compliance
and keep management informed of environmental performance. Why is this
important? If you ask these companies, you will generally hear this reason
liabilities resulting from noncompliance with environmental regulations
can be severe, and include both monetary penalties and personal exposure
at top management levels.
industry leaders in both manufacturing and utilities have discovered two
other reasons to optimize environmental performance
is product lost to the environment, and the cost savings associated with
pollution prevention are significant. Companies are reporting saving millions
of dollars over a period of a few years.
conditions have changed. Consumers, customers, and even investors want
to know what companies are doing to manage environmental issues and grow
a sustainable business. These concerns are a buying influence that are
rapidly mounting due to global changes in political structures, societal
demand, and deregulation.
of the most useful elements of an environmental management strategy is
a proactive internal audit program that reports how a companys environmental
management program or system is working before regulatory agencies and
other stakeholders detect problems.
start auditing themselves to collect objective evidence of meeting their
environmental goals related to compliance and EMS performance. Both the
U.S. EPA and the International Organization for Standardization (ISO)
have policies and guidance related to environmental self-auditing or internal
auditing. How are these audits conducted? They are typically performed
by trained personnel from within the company, external consultants, or
a mixture of both depending on in-house resources and competencies. Regardless
of who performs the audit, it is important that the auditors strive for
objectivity while conducting the audit. The internal audit typically involves
document and data review, followed by on-site interviews and observation
of plant activities. Effective communication with the auditee is essential
before, during, and after the audit to ensure complete information and
results are obtained that are useful for management decisions. While available
environmental data may be reviewed, environmental sampling is not a part
of the auditing process.
the difference between auditing compliance and EMS performance? Compliance
is only one component of environmental performance, and focuses strictly
on meeting environmental regulations and requirements of federal, state
and local agencies. Compliance is frequently measured in numbers of violations.
While compliance auditing is essential to risk management, it does not
guarantee optimal internal efficiency or necessarily meet the environmental
concerns of consumers and customers. EMS performance requires going beyond
being "in compliance" to consider significant environmental
impacts at their source, and targeting these sources for reduction. Optimal
environmental performance may eventually involve complete reuse of materials
in industrial processes to approach zero waste generation.
to ISO 14001, the internal audit program should define procedures that
activities and areas to be audited
frequency of audits
responsibilities associated with managing and conducting audits
communication of audit results
audit program and schedule are based on the environmental importance of
a particular activity and the results of previous audits. For example,
a shipping and receiving department may have the potential for significant
environmental impacts depending on the procedures followed to handle certain
types of cleaning solvents or R&D materials. The rest of the materials
received may be inert or non-toxic. If the companys environmental
objectives were waste minimization and accident reduction, it may
be important to audit the departments procedure for handling these
materials, and check records of previous audits to see whether these procedures
had historically been followed.
multi-media checklist has proven to be a valuable tool for conducting
internal audits. When designed correctly, the checklist serves the dual
purpose of providing a consistent format for evaluating compliance and
environmental performance and establishing a baseline to be measured against
during subsequent audits to track progress and report results.
Checklists are tailored to industry issues and the facilitys environmental
compliance program or management system to be relevant and concise.
resources required to conduct audits will depend on the companys
size and complexity of operation. The following factors will increase
the resources required:
initial audit vs. follow-up surveillance
of employees and departments
structure and complexity
of technology and variety of products the companys record
important to resources is the management support demonstrated regarding
the importance of the internal audit. Senior managers tend to pay major
attention to audit results, given the concerns of customers and other
commitment, resources, and audit tools such as checklists are the keys
necessary to running an effective internal audit program. A customized
checklist that auditors use to consistently evaluate the environmental
management program or system will reduce the time required to conduct
the audit and be audited. These checklists vary greatly in content and
detail depending on the goals management expects to accomplish via auditing.
Some companies believe a very detailed audit is necessary to evaluate
their programs. These companies implicitly subscribe to a "management
by inspection" approach to ensure employees are doing what they are
supposed to be doing to manage the environmental aspects of the operation.
The advantage is a thorough evaluation, but the down side is a significant
investment of employee time, both auditor and auditee, to answer the detailed
questions. Employees can also be resentful of others "looking over
their shoulder" to ensure work is being done the right way.
a growing number of companies are realizing that environmental performance
is enhanced where employees are involved in setting environmental objectives,
delegated responsibility and held accountable for meeting environmental
targets. Audits then focus on evaluation of the system and procedures
to set and meet the objectives. These companies are able to accomplish
audits using simpler checklists that reduce auditor and auditee time,
shortening the duration and frequency of audits.
easy-to-use audit checklist was developed by the auto service and body
repair industry. A national group, the Coordinating Committee for Automotive
Repair (CCAR) originally developed the checklist, which is currently
available at the www.ccar-greenlink.org
checklist is simple and concise, question and answer two pages
broken down into four major categories of environmental impacts:
major category is then further subdivided into more specific sources of
impacts. For example, waste management impacts are first characterized
as hazardous or nonhazardous for compliance estimation; then each waste
stream is evaluated. For the auto repair industry, this meant 20 questions
regarding the handling of used oil, used oil filters, used antifreeze,
used solvents, batteries, rags, tires, and absorbents. Responses were
in the form of yes/no or multiple choice to facilitate analysis of results.
checklist served to estimate compliance and sensitize shop owners to their
current environmental management practices. It highlights areas where
alternative management practices would enhance environmental performance
through pollution prevention.
auditing is beneficial. The biggest expense is employee time, and time
can be saved if a systems approach is employed and employees are delegated
responsibility for developing and implementing the system.