An Environmental Audit Program

WHY DO AN AUDIT? There is increased enforcement of environmental laws and regulations at State and Federal levels with attendant steep fines and even the possibility of jail sentences. We are all aware of environmental and public health and safety incidences (i.e., Love Canal, Bhopal) which have led to stringent laws and regulations (i.e., CERCLA, RCRA, SARA). In some cases, the courts have specified that a company institute an audit program as a condition of settlement of claims which related to lack of environmental control. The U.S.EPA issued an Environmental Auditing Policy Statement in the November 8, 1985 Federal Register (pp. 46504-46508) which encourages the use of environmental auditing by regulated entities. Elements of what EPA considers to be an effective environmental auditing program are outlined and briefly explained. These factors combine to indicate why there is a growing number of companies which have instituted an audit program. Briefly, the program can and should be used to monitor compliance with environmental regulations and corporate policy, to prevent violations, to improve policies and procedures, to raise the level of environmental awareness, to encourage communication among operations and all management levels about environmental problems, and to measure risks and control costs. AMAX Inc. has had an environmental audit program since the early 1970's. The AMAX Environmental Affairs Department, working with the Law Department, oversees and coordinates environmental audits and analyzes the findings which an audit reveals. Facilities are audited on a regular schedule; those having the greatest potential for environmental liabilities are audited at least annually; other facilities are audited less frequently. The question of who performs the AMAX audits was settled in favor of the audit team being independent of personnel from the facility being surveyed. Other methods of auditing could be the following: - Independent contractor (Appendix A) - Combination of independent contractor and in-house staff - Self-audit by site personnel The merits and demerits of who should conduct the audit can be analyzed to suit your particular needs. Next you need to decide on the procedure for the audit and the form for reporting and follow up. Environmental publications referenced in Appendix B can be helpful to you at this point. After deciding on the form of auditing, a schedule is prepared and followed to the closest extent possible. This schedule should be published and distributed to the sites so facilities know when they are being audited. This is not designed to be "a game of hide and seek." Various elements of the AMAX Audit Program are as follows: Team selection Pre-visit preparation Site visit Exit interview Report Using the audit Follow-up Team Selection The usual make-up of the team is the audit manager, the environmental specialist who normally provides assistance to the site or has knowledge about the operation, and a legal representative if his or her schedule allows. The legal representative will review the findings of the audit team if a personal visit is not timely or necessary. Size of the team can be expanded, but a minimum of the audit manager and the environmental specialist is best. Two sets of observations are better than one. The environmental specialist can also provide the rapport which is beneficial to creating the appropriate tone so that the site people will be as cooperative as possible. This is not to be an antagonistic exercise.