EHS Audit Overview

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


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


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”


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!”


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


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.


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).


Sample Root Causes of Audit Findings

16

338

9 Procedures

Equip./Facility Design

Management

Document Mgmt.

Unaware of Applicabilityof Regulation

39 Total Findings


Sample Corrective Action Plan

FindingRoot

CauseCorrective

Action PlanPerson

ResponsibleDue 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 Implemented

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 Implemented

Submit missing Tier II Hazardous Chemical Inventory report(s).

Mike Stevens; ThermoRetec to support

Q4 1999

Completed 1/10/00

These are short-termsolutions only. Long-term solutions need toaddress root cause.


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.


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!!!

EHS Management Strategies, LLCGreenhouse 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 ProgramsEHS Management Strategies

EHS Management Strategies, LLC

James Charles, PE

Senior [email protected]

(616) 666-5490

WWW.ISO14001-Training.com


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EHS Audit Overview