Environmental, Health and Safety Audits – Tips for Success!

Since the early 1970s, private industries have recognized the benefits of conducting environmental, health, and safety audits at their regulated facilities. In general, the purpose of an environmental, health and safety audit is to ensure compliance with the myriad of environmental, health and safety regulations promulgated by the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA) , the Nuclear Regulatory Commission (NRC) and many other federal, state and local agencies. Additionally, contemporary audits include implementation of environmental health and safety management systems, such as ISO 14001 and OHSAS 18001, and compliance with corporate standards or guidelines. For a successful environmental, health and safety audit, the author offers the following tips:

1. A lead auditor should be assigned. This person will have primary responsibility for assembling the audit team, defining the audit scope, preparing the audit agenda and plan, reviewing the draft report, and following up on any required corrective actions upon completion of the audit.
2. You will need to assign a primary site contact. In most cases, this contact will be an environmental, health and safety manager or someone with similar responsibilities. This person must have access to all relevant environmental, health, and safety records and permits, and must have unimpeded access to all physical areas of the facility. Also, verify that the site’s primary contact is communicating with the most senior member of management at the site about the audit and the audit schedule. Nothing causes more of a stir than performing an environmental, health and safety audit at a facility where the senior management team is unaware of its occurrence. Of course, if your company has a policy that “surprise audits” are acceptable, then that’s a different story.
3. Pre-planning for an environmental, health and safety audit is just as important as the audit itself. Much of the success of an environmental, health and safety audit program depends on careful planning. At least two weeks prior to site activities, the lead auditor should prepare and distribute an agenda to all involved personnel, including the site contact.
4. Please provide a list of requested documents and programs to the site contact. The audit team should receive copies of these documents well in advance of on-site activities. Important documents to include on this list are regulatory permits such as air permits, wastewater permits, radioactive materials licenses, stormwater permits, etc. Written programs and associated training materials for regulatory programs such as hazard communication, chemical hygiene, respiratory protection, bloodborne pathogens, and hazardous waste management. If you are not sure if any of these programs apply to a particular installation, please go ahead and list them and provide the respondent with the option “not applicable”. For larger installations, having a sitemap can also be helpful.
5. Review written documents. The amount of time you will have on the site will generally be limited to one week or less. For larger installations, you should use your time on site wisely. To the extent possible, review as many written documents as possible prior to on-site activities. Take notes of important items you will want to check during on-site activities. Prior to on-site activities, re-familiarize yourself with important regulatory requirements and review state and local requirements.
6. Review publicly available databases for site regulation information. Go online to the various regulatory databases maintained by OSHA, EPA, and state agencies to view historical information on regulatory inspections, air emissions, hazardous waste generation, etc. What you are looking for is to determine the regulatory history of the site and any previous history of violations. If there have been violations in the past, when you are on the site you will want to verify that systems are in place to prevent repeat violations.
7. Refine the schedule. Based on the document review, refine the agenda so that there is sufficient time to review items where there may be concerns or areas where there may be increased risk. Don’t waste your precious time on the site on trivial matters.
8. Make sure the site’s primary contact has spent adequate time. Nothing is more frustrating for an audit team than having a primary on-site contact who is constantly leaving for other meetings or other tasks. In addition to dedicating adequate time for the audit team, the primary site contact should also reserve an adequately sized conference room, with Internet access, and that can be secured overnight. During an audit, you will work long hours and review many sensitive documents. You don’t want to waste time having to pack up your supplies at the end of each day.
9. Once on site, hold a keynote address. People who should be at this opening conference include members of the audit team, the primary site contact, key operational personnel and, if available, the site administrator. During the opening conference, introductions, review of the agenda, purpose of the audit review, key schedule elements, and timing of the closing conference should be made. In addition, the personal site must indicate if any special activity is taking place that prevents them from being available for questions.
10. After the keynote, I usually like to take a short tour of the facility. This tour should not be of any significant detail, but rather a tour to get acquainted with the facilities. Make notes of areas you will want to return to for further examination.
11. Compare statements made in plans and schedules with actual records and activities. Discrepancies between the two may be an indication of gaps in the program.
12. At the end of each day, the audit team should meet with the site’s primary contact to review any unanswered questions. Provide the site’s primary contact with a list of possible findings or areas that need further investigation. In many cases, these items can be resolved simply by locating the correct records.
13. The night before the closing conference, make plans to make it a long night. You will need to prepare a preliminary list of audit findings. Audit findings should be written as accurately as possible. Avoid subjective terms such as “all”, “many”, “poor” or “inadequate”. Provide evidence to support your findings. If further investigation is needed, please indicate so.
14. Hold the closing conference. On the last day of the audit, a closing conference should be held. It is preferable that the same attendees who were at the opening conference are present. During the closing conference, the audit team should thank everyone for their time and cooperation, all preliminary audit findings should be reviewed, key concerns should be expressed, and a timeline and distribution list should be provided for the audit. Preliminary report. It is important that all findings to be included in the draft report are presented. There should not be any surprising conclusions in the draft report.
15. Prepare and send the draft report to the distribution list for review. Ensure that the distribution of the draft audit report is controlled. In some cases where there are significant regulatory findings, email distribution of the draft report should be avoided. Hard copies of the draft report, sent by overnight express delivery, may be preferred. If there are significant regulatory findings, consult your company’s legal counsel before distributing.
16. After reviewing and commenting on the draft report, finalize the report and prepare a corrective action plan. This is the most important part of any audit. Now that the deficiencies have been found, corrective actions must be taken. A process to track completion of all findings, priority, and responsible person(s) is absolutely necessary. The failure to correct the deficiencies found in a timely manner can represent a significant liability for the company. Simple and affordable corrective action software systems are available and should be considered a must for any environmental, health and safety audit program.

Conducting an environmental, health, and safety audit is a valuable tool for improving EH&S performance at a given location. However, to be successful, the audit team and site personnel must carefully plan the audit and ensure that corrective actions are followed up properly.