What to Expect During an Environmental Audit
December 17, 2019

When you are expecting an environmental audit, it can be extremely stressful, especially if you do not know what to expect. The EPA (Environmental Protection Agency) puts a lot of emphasis on their audits, so it is in your best interest to understand how to prepare for yours.

What is an Environmental Audit?

The Environmental Audit is a systematic, periodic, objective, documented process done to assess your business’s services and activities in relation to:

  • Evaluating your compliance with internal and statutory requirements
  • Ensuring you are facilitating management control for environmental practices
  • Making sure your business is promoting proper environmental management
  • Checking if your business is maintaining credibility with the public
  • Ensuring you are enforcing staff commitment to departmental environmental policies
  • Looking for any ways you can improve opportunities
  • Provides you a performance baseline to develop Environmental Management Systems

The environmental audit is not an option; it is a sound precaution in today’s heavily regulated environment. The EPA has a valuable role in encouraging the systematic use of environmental perspectives in a facility’s overall operation. It is their mission and goal to trigger and implement awareness and new priorities to protect our world.

Have Paperwork in Order for an Environmental Audit

Any good auditor is going to ask you for your environmental record-keeping paperwork. You will want all these documents in order if you want to pass your audit. Your documentation is proof that you are complying with EPA regulations. If you are missing any piece of evidence, or cannot prove you completed a required report, you could fail the audit.

Not only do you want to make sure you have all the proper paperwork, but you also want it organized and kept in a professional manner. Don’t have the auditor appear with you having to shuffle through piles of papers to find the documents they are asking to view.

There are protocols set by the EPA for an EHS (Environment, Health, and Safety) audit, which include features of your record-keeping methods being an essential piece of an audit. When the auditor arrives they will look for:

  • Your MSDSs (material safety data sheet) for all hazardous materials, and whether or not you have them accessible to employees who would have contact with them.
  • Your contingency plans for an emergency response
  • All documentation regarding any incidents, accidents, or spills that have occurred. They will also want to see your Emergency Response Notifications that were sent to the EPA in regard to these events.
  • They will want to see proof you have developed a pollution prevention plan. You may not have been required to have a pollution plan as not all businesses are asked to perform these. Having one, however, is a good idea and could show the auditor you are committed to running a top-shelf facility.
  • Your chemical inventory forms must be present and must match your actual physical inventory. These forms will also be checked to make sure you are keeping a record of the actual chemicals you have in inventory.
  • Your proof that you have met all federal and state requirements, along with your required compliance reports such as the TRI Form R.

The TRI Form R Needed for an Environmental Audit

The TRI or Toxic Release Inventory Form is your annual report if you process or manufacture hazardous chemicals in your business. It is due by the first of July every year, and you have to report the quantity of TRI chemicals and how your business uses these chemicals. This report must be done using the EPA’s TRI-MEweb system.

Not all businesses are required to report, and the EPA has set thresholds for this reporting process. If you are not sure if your business is required to report, you can check with your local hazardous waste service to find out the guidelines on your reporting requirements.

The TRI report, if you are required to report, is one of your most significant calendar events for environmental compliance. Most businesses begin weeks or months before the reporting date to ensure all their information is submitted on time. Work with your local hazardous waste service on this report as it can be one of the most stressful times of the year in regards to required reporting.

Physical Inspection of an Environmental Audit

The auditor will conduct a physical inspection as well as the one of your paperwork. They will want to look at the physical features of your facility and the possible generation of hazardous releases. They will be looking at your chemical storage areas, shop floors, and your end-of-life related locations. These locations include:

  • Disposal sites
  • On-site surface impoundments such as lagoons or ponds
  • Treatment units
  • Recycling units

The inspection is also going to include questions presented to you on how you obtain your sources. They will ask about what materials are used in your facility and what your control devices are that you have put into place. Along with wanting to know which control devices you use, they will ask about how effectively they work. The auditor will be concerned with how you control leaks, spills, emergency shutdowns, and fugitive emissions.

Your audit is also going to include an inspection of your sources that require regular maintenance tune-ups, such as your boilers. You will need the necessary paperwork to prove maintenance schedules have been followed.

What to Expect From Your Environmental Auditor

An environmental auditor should have personal attributes that include open-mindedness, tact, perceptiveness, and ethics. The auditor should understand audit techniques, principles, procedures, and have experience from conducting past audits. The auditor should also know the subject matter they are auditing and how it applies to other organizations.

Environmental auditors should have good communication and leadership skills and be able to resource and plan effectively. They also should have completed training courses on audit procedures and have attained an appropriate level of education. An environmental auditor should have adequate experience and skills for the job.

Benefits of the Environmental Audit

The environmental audit helps to safeguard our environment and our natural resources. It ensures businesses are complying with international and domestic environmental laws. There are three types of environmental audits:

  • Environmental Compliance Audits
  • Environmental Management Audits, which verify if a company meets its stated objectives
  • Functional Environmental Audits for such services as electricity and water

The benefits of the audits vary depending on the scope and objectives of the audit. Some of the environmental auditing benefits include:

  • Improving the environmental performances of businesses and saving them money
  • Making sure businesses understand how they are expected to meet their legal requirements
  • Help facilities understand how they can develop and implement environmental interactions of their services, products, and activities
  • Make sure facilities are meeting specific statutory reporting requirements

The Downside to the Environmental Audit

While there are many benefits to having an environmental audit, there are also some drawbacks. The audit helps to maintain your compliance with required regulations and ensures your facility is operating safely for both employees and the environment; however, there are some potential negatives:

The EHS audit normally includes a survey of your workplace to:

The benefits of an audit outweigh the negatives as they keep your facility safe for your employees, you, and the environment we live in.

Final Tips on the Environmental Audit

The auditor is going to be ensuring your paperwork matches up with your environmental records. You want to be sure your facility and your paperwork are in order. If you’ve done your EHS management correctly throughout the year, your audit will not be a problem.

There are three main tips to keep in mind when facing an environmental audit:

  • During an environmental audit, there may be issues uncovered that you were unaware of and which may not be simple or inexpensive to correct
  • It is imperative you correct problems the auditor has identified; otherwise they can lead to potentially more serious issues. Fixing issues in a timely manner is an essential part of an environmental audit.
  • You may want to check with your local hazardous waste disposal service for counsel on whether or not you are required to report your audit information to OSHA or the EPA. As a general rule, disclosure of internal audits are not required to be reported.
  • Verify or identify which regulations apply to your facility
  • Verify that your employees are following the environmental and workplace requirements for safety
  • Assess the methods you have in place and that your systems are in place to ensure compliance
  • Having a checklist of things to look for will help guide your auditor through the inspection and remind them of all areas in the scope of your inspection. The checklist will by no means be all-inclusive, and your auditor should have a paper with space to write notes.
  • Once your audit is complete, you should begin implementing any recommendations the auditor has suggested. If you need assistance with these changes, your local hazardous waste disposal service may be able to help you put the changes in place.
  • Make sure you meet with any employees that will be affected by the changes and ensure they understand their role in making sure the changes are effective.
  • A good rule of thumb for preventing hazards in the workplace is to always be on the lookout for hazards that could threaten human health or the environment. When located, make sure these threats are addressed with the most efficient way to control and prioritize them.
  • Make sure you have completed all required reporting. If you are missing even one report, you won’t pass the audit.
  • Make sure you have not missed any changes or updates to relevant regulations. Check with your local hazardous waste disposal service to see if anything has changed and to ensure you are up to date on it.
  • If you had any issues brought up in your last audit, you want to make sure these have been addressed. You could face higher fines for repeated noncompliance with previous feedback given by the EPA.
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