An EHS audit is a critical component of your EHS management system. It assesses your compliance with applicable Environmental Protection Agency regulations and Occupational Safety and Health Administration standards to ensure that your management system works as intended.
How should you prepare your facility and staff for an EHS audit?
You need to prepare your facility to be subject to an EHS audit.
- Determine the scope and focus of the audit. This is often determined by areas of risk, past audit findings, violations, and recent incidents.
- Establish an internal team with auditors. You can draw on your EHS management, regulatory affairs management, or contract with a third-party auditing service.
- Create checklists and protocols to help your auditing team. Consult your regulatory registryYou must be aware of the applicable safety, health, environment and environmental regulations to your facility.
- The audit should be scheduled when the facilities and auditing teams are available;
- Notify department managers about the pending auditor so they can collect all documentation, logs policies, practices and procedures that the auditors need.
How do you select your Auditing Team for an Audit?
EHS audits require skilled and knowledgeable professionals. You may prefer to have your own internal auditing team, even though some companies might hire an outside firm to manage their audits.
If you use internal auditors, three to five people from your EHS or regulatory affairs or operations departments should be able to confirm that they are familiar with all EPA statutes and regulations. They should also be able to identify regulatory violations and hazard identification. Auditing teams should not be assigned the task of checking their own departments or teams in order to ensure objective audit reports. You need new eyes and ears to look at compliance. They might spot an issue that your managers and supervisors may not see.
What does your Auditing Team need to do in preparation for an audit?
It is important that your auditing team reviews audit reports from previous audits and the corrective actions taken. They should begin with a detailed list detailing the findings of both closed and open audits.
The auditing team may also need to be updated on your facility’s compliance obligations, including permit requirements. They should be informed about regulatory changes such as new controls or limits, or revised training and recordkeeping. They will also need to be familiar with your organization’s internal policies and procedures.
Your EHS management system should include auditing and recordkeeping functions, as well as your regulatory profile, which includes all activities, equipment, or processes that occur in your facility. Technology can helpHowever, you should also have Placement of processes Make sure that your teams are constantly reviewing regulatory changes and assessing the impact they have on your facility.
What Should Auditors Checklists Contain?
No matter what the scope of your audit, checklists must address every requirement in the laws or regulations that apply at your facility. An audit team can use a compliance profile (or regulatory register) to identify the requirements that are applicable to your facility.
How Often Should an EHS Audit Be Performed?
It can be difficult to determine the right frequency and schedule for EHS audits. If you schedule EHS audits too frequently, your supervisors and managers might become complacent, and only start to increase their compliance efforts when the audit date approaches. On the other side, auditing EHS compliance too often can leave your employees feeling overwhelmed and unable correct any deficiencies found in the last audit.
You might want to balance periodic formal audits with routine checks for compliance in certain areas, departments, and workflows. Some companies combine routine audits done by EHS staff with periodic comprehensive audits conducted by third-party auditors.
Not all business units should be audited at the exact same frequency. For example, compliance audits at manufacturing facilities may be more frequent than those at warehouses and logistics centers or administrative offices. You can also assess the frequency of compliance audits by assessing the risk of any chemical, physical, or processing hazards found in each facility.
You will also need to decide the day and time you want to conduct your audit. An audit that is scheduled for the busiest day of production would be disruptive. A production shutdown audit would provide little insight or value.
What should you do about your audit results?
Two end products must be provided by your auditing teams: a comprehensive report and a detailed description. An audit report will summarize all that your auditors reviewed of the written documentation of your department, team or department, work practices and procedures along with auditors checklists and measurements.
A completed EHS audit could reveal deficiencies in your compliance program. You must evaluate your findings if your audit identifies areas that are not in compliance. Corrective actions takenIf necessary, Corrective actions must include details of the issue and references to relevant regulatory citations. You should also have a system in place to track corrective steps to closure and verify that they were completed correctly. Again, These processes can be automated with softwareBy providing alerts for overdue activities and visibility into the status pending items
Audit results may also indicate the need for higher-level action. An EHS audit could indicate that you need to reevaluate and update your EHS policies.