Vicente Sederberg LLP| Vicente Sederberg LLP

EHS audits can be conducted in many ways: during acquisitions and sales, regulatory agency inspections (scheduled and unexpected), internal company requirements, maintenance and certifications, and during acquisitions and/or sale. Part two of the three-part VS Insights series on EHS audits will focus on the EHS audit day. (If you missed it, please read Part 1: How To Prepare.)

While it can be stressful to prepare for an audit ahead of time, nothing compares with the moment an auditor walks in your door. Let us help you overcome the fear of the unknown. We will also give some tips to reduce stress and improve your chances of a flawless audit day.

Personnel Considerations

How your personnel responds to the auditor’s questions can make or break an audit, so make sure your staff is well-equipped to answer questions. Management may be aware that the auditor is coming to their office, but not certain departments. Although not mandatory, it is recommended that a companywide meeting be held in this instance. At a minimum, it’s best to speak with department managers or those heavily involved with an audit area so they are prepared and ready to answer any potential questions the auditor may have.

In the case of a surprise audit, it’s best to have a plan in place ahead of time. This plan should include who greets the auditor, and who is responsible for informing on-site and off-site staff.

EHS Audit Day Basics

As we discussed in Part oneAudits can cover everything from worker safety checks, to compliance with federal and state environmental regulations. While there’s no set template, audits are typically performed in the following steps:

Step 1: Pre-meeting

• Audits usually begin with a meeting between the auditors and the management personnel to discuss the purpose of the audit.

• Discuss whether photography is allowed, especially if it’s an external audit.

Step 2: Inspection at the Facility

• Before the auditor enters your facility, inform them of any safety requirements.

• Once the auditor is ready, he will inspect the facility for compliance with regulatory requirements. This could include checking product storage, water drainage systems, or waste removal processes.

Step 3: Paperwork Review

• Next is a review of the internal operations. The auditor will review the operation of the facility and its departments, worker safety and health, and overall facility operations.

• Examples include reviewing the standard operating procedures of a department and business records to verify certification compliance for the past year.

Step 4: Interviews

• Auditors will often interview business personnel and inspect records and documents that are relevant to the audit.

Quick Tips for the Big Audit Day

1. Answer honestly and truthfully It seems simple enough, but it’s crucial to answer honestly. It is much better to say “I don’t know” or “I don’t have that document” rather than be caught in a lie.

2. Don’t hide or create information.Give only the information that you have available. (Don’t run into a back room and try to quickly whip up a document and back date it.)

3. Be calm and politeAuditors are just trying their best to do their job. A little kindness can go a long ways.

4. Stay organized.You want an auditor to arrive quickly. The faster the audit process will go, the more organized you can be in terms of how documents are placed and how they flow through the facility.

5. Don’t assume what’s being asked. If you’re not clear about the question, ask for clarification.

6. Plan ahead for your facility tour. Take safety precautions into account and find a route that addresses all major inspection topics.

7. Keep everyone on the exact same page.Meet with employees and department heads to ensure they are familiarized with the audit topics.

8. Make copies. Make sure that the auditor has the necessary files and copies available for review. The quicker they can go through the records, and the faster the audit will be completed.

9. Take photos of everything the auditor takes. You never know when facility photographs might be swapped. Make sure you document all photos that the auditor takes. You can even offer to take the photos and send them to auditor.

Audit days can cause increased stress for everyone involved in the business. We hope this information helps to prepare you for what is ahead and offers some tips to help you get your cannabis business through a long, exhausting day.