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Environment, Health & Safety (EHS), Audit: How Can Cannabis Businesses Prepare | Vicente Sederberg LLP

Environment, Health & Safety (EHS), Audit: How Can Cannabis Businesses Prepare | Vicente Sederberg LLP

[co-author: Jace Pohlman]

There are many types of audits in the Environmental, Health, and Safety (EHS). These include regulatory agency inspections (scheduled and unexpected), internal company requirements, maintenance and certifications, and during an acquisition or sale. Stress can be high even during a scheduled audit. Although yearly preparation is the best, there are still ways to prepare for the audit.

This three-part VS Insights series will take you through an EHS audit, from pre-audit to after-audit. We’ll also share tips and tricks along this journey.

Preparation for the Pre-Audit

Why do an internal audit?

Your business can have internal audits to ensure compliance with various EHS regulations. These regulations protect workers, the environment, and the community. Internal audits offer a chance for cannabis companies to improve in areas that they may not have considered. This includes creating a culture where compliance is a top priority for employees and management.

Audits allow cannabis businesses keep up-to-date with the legal requirements of their business. This is especially important for the cannabis industry, which can see changes in laws and rules every day. Last but not least, a consistent audit schedule can help you avoid regulatory fines for noncompliance and save money on correcting deficient operations.

What are the reasons a cannabis facility might be subject to an outside audit?

Cannabis agencies are under the jurisdiction of several federal, state and local agencies. The following EHS-related organizations are included:

  • OSHA (Occupational Safety and Health Administration) – protects workers
  • EPA (Environmental Protection Agency) – federal environmental agency
  • State environmental agencies

What areas of focus will an EHS Audit include?

  • Air quality
  • Risk assessments
  • Prevention and control of spills
  • Emergency planning – fire safety
  • Industrial hygiene
  • Solid and hazardous waste
  • Water discharges
  • Air emissions – emergency generator, solvents
  • Storage tanks
  • Chemical reporting
  • Powered industrial trucks
  • Hazard communication
  • Personal protective equipment
  • Fire protection – flammables storage
  • Respiratory protection

This list does NOT include all types audits. Multiple topics are covered in single audits.

Pre-Audit Tips

  • Scope

    • Is the audit a regulatory agency inspection or a worker safety compliance check? Knowing the reason your business is being audited can help you determine what information and records are needed. This will prevent you from having to rush to prepare documents or files for the auditor.

  • Keep Your Eyes Open

  • Inform personnel

    See Also

    • Not all personnel need to be involved in an audit, but it’s important to explain to staff why people are wandering through the facility and how they should respond to questions if an auditor approaches them.

  • Stay “Audit-ready”

    • You can keep track of audit topics throughout the year so surprises are not a problem. This will increase reliability and help build relationships with auditors by having the necessary information at their fingertips quickly and efficiently.

Audit day can be stressful for everyone involved. These preparation tips will help you understand what auditors are looking to see and how to prepare your cannabis business for them.

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