Minding Your "P"s and Cues

• By Sultan I. Amer, PhD
• Mar 01, 2002

Environmental auditing goes much further than determining whether a CEO adds a topic titled "Environmental Status" to his or her monthly staff meeting agendas or verifying that the company's purchasing agent request MSDS's from suppliers or seeing the environmental engineer's signature on funds requested for capitol projects. Comprehensive environmental auditing includes assessing a facility or business unit's six "Ps". The six "Ps" are the environmental policy, plans, programs, projects, protocols and procedures.

All environmental professionals know it is the duty of responsible management to ensure that the environmental policies and strategies are realized. One of the specific commitments should be that the organization will develop and implement a continuing program to assess the environmental management systems and plans of each facility or business unit. This program should include:

• Periodic environmental assessments of the six "Ps" at each facility and/or business unit;
• Employee training programs to insure an understanding and dedication to the organization's environmental assessment programs;
• Periodic reports on compliance performance, and on corrective and preventive measures undertaken;
• Immediate notification of organization management of compliance problems or allegations of violation of environmental laws and regulations; and
• Immediate corrective response to such occurrences.

An organization's environmental audit and assessment program should be designed to promote a high level of environmental integrity at all of its operating facilities and business units. It will also be an educational program providing management with an increased awareness of environmental protection requirements, and an evaluation of existing internal environmental programs, and an identification of strengths and deficiencies.

An organization's environmental audit and assessment program should be designed to promote a high level of environmental integrity at all of its operating facilities and business units.

To enhance consistency and reliability, the environmental audit or compliance assessment should be conducted according to documented and well-defined methodologies and systematic procedures. Assessments and audits should be conducted in accordance with written protocols. Six essential elements of a good protocol include:

• An abstract or overview of the various regulations which may be encountered including international, federal, state and local;
• A dictionary covering specific key regulatory definitions, which the auditors need to know;
• Appropriate inspection items should be covered and address potential environmental problems;
• A listing of appropriate internal guidance and procedures;
• The protocol should provide specific tasks, which could help evaluate the organization's compliance status and environmental posture; and
• The protocol's checklists should provide plenty of space for comments.

To ensure the objectivity of the audit process, its findings and conclusions, the audit team members should be independent of the activities they audit. The audit team members should possess an appropriate combination of knowledge, skills and experience to carry out their audit or assessment responsibilities. It is advisable to have audit team members highly knowledgeable in the following areas:

• Air pollution control;
• Water pollution control;
• Waster management;
• Toxic substances control;
• Right-to-know and labeling; and
• Environmental emergency prevention, control and countermeasure programs.

The environmental assessment team must have expertise in environmental protection, laws and regulations, manufacturing operations and processes, environmental control technologies, management and safety systems, scientific disciplines needed to identify potential problems and a state-of-the -art understanding of industrial environmental and product stewardship programs. The assessment team must also have a collective understanding of the facility and/or business unit that is accurate and complete, and must be able to communicate its understanding to others during and after the assessment. Steps to obtain this understanding include:

• Review of pre-visit questionnaires;
• General review of process, flow diagrams and permits requirements;
• Review of historical performance record;
• Compare procedural controls against practice;
• Review facility's techniques for identifying and evaluating hazards and risks;
• Discussions with facility's and/or business unit's staff and operating personnel;
• Facility tour;
• Review of files and records;
• Detailed note taking using checklists;
• Review of facility resources and programs (Personnel, training, equipment, available expertise, etc.); and
• Review of facility and laboratory procedures.

When the on-site audit has concluded, the results of all investigations should be reviewed in detail with facility and/or business management and also the entire audit team as part of an exit interview. The audits finding can be prepared and presented in the following manner:

• Complete worksheets, summary fact sheets and checklists for use in developing the final report;
• Individually prepare a list of audit findings and results;
• Evaluate strengths and weaknesses; and then
• Discuss findings, evaluations and recommendations with the facility manager and appropriate staff before leaving the facility.

To ensure the objectivity of the audit process, its findings and conclusion, the audit team members should be independent of the activities they audit.

In developing the written audit report, the team should bear in mind that the report will be used for:

• Management notification and information;
• Initiating corrective and preventive actions;
• Employee training; and
• Documentary evidence.

The key principles employed in the final report should be:

• The scope of the assessment/audit;
• The reporting of facts; and
• The highlighting of good features and problem areas of the six "Ps".

The key elements of the final report are:

• An executive summary; and
• The summary fact sheets.

The final should be composed of an executive summary and profile that has been developed from the worksheets and summary fact sheets developed by the audit team as support for the conclusions and findings of the audit. Elements of the executive summary should include:

• Identification.
This should include the identification of the organization, facility and/or business unit audited, as well as the dates and period covered by the audit.

• Confidentiality.
This should include a statement of the confidential nature of the audit report and a restricted distribution list.

• Objectives of the Audit.
This may include: compliance status; ISO-14000 compliance training of personnel; determination of sustainability or growth constraints; and providing operation of an executive management with an in-depth assessment of a facility's and/or business unit's environmental programs.

• Organization of the Audit Team.
Provide a brief identification of team members as well as facility and/or business unit staff who may have supported the team during the audit.

• Regulatory/Legislative Programs Audited.
Include a brief description of government programs subjected to the audit

• Conclusions.
Make a brief statement to characterize the environmental management programs for the facility and/or business unit.

• Noteworthy Items.
Briefly highlight exceptional environmental plan, programs, projects, protocols and procedures.

• Items for Further Action.
It is here that existing problem areas must be presented. This section should provide recommendations for follow up by the facility and/or business unit based on the information in the summary fact sheets. It is important that the summary fact sheets provide action items required addressing sufficiently the potential problem areas identified by the audit.

• Bold Objectivity.
Last, but not least, as an environmental professional conducting audits and assessments, you must be objective and adhere to the requirements of your code of ethics.

Attend the National Registry of Environmental Professional's Registered Environmental Manager (REM) and Certified Environmental Auditor (CEA) workshops April 10-11 in Seattle, Wash., April 30-May2 in Nashville, Tenn., and May 8-9 in Philadelphia, Penn. Visit www.nrep-bowman.org or call 770.486.9253 for more dates and locations.

This article originally appeared in the March 2002 issue of Environmental Protection, Vol. 13, No. 3, p. 30.

This article originally appeared in the 03/01/2002 issue of Environmental Protection.