EVOLUTION OF AN ENVIRONMENTAL AUDIT PROGRAM
J. H. Maday
T. L. Kuusinen
October 1991
Presented at the
Environmental Auditing Conference
October 22-23, 1991
Seattle, Washington
Work supported by
the U.S. Department of Energy
under Contract DE-ACO6-76RLO 1830
Pacific Northwest Laboratory
Richland, Washington 99352
DISCLAIMER
This report was prepared as an account of work sponsored by an agency of the United States。Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.
Evolution of an Environmental Audit Program
Joseph H. Maday, Jr. (ASQC-CQA)
Technical Group Leader - Quality Verification Department
and
Tapio Kuusinen
Senior Research Scientist
Environmental Policy and Compliance Group
Pacific Northwest Laboratory
Richland, Washington 99352
ACKNOWLEDGEMENT
This document was prepared under the direction of the U.S. Environment Protection Agency’s (EPA)
Small Business Division. There were numerous reviewers from government and private organizations. Additionally, the following provided important advice and/or reference materials:
* Small Business Ombudsman, Maine Department of Environmental Protection
* Tennessee Small Business Assistance Program
* New Jersey Department of Environmental Protection
* Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA)
* Iowa Waste Reduction Center, University of Northern Iowa * Florida Small Business Assistance Program
The products and services included in this document were contributed for review by commercial and
government sources. The project team is thankful for their timely cooperation.
ABSTRACT
International and national standards, and in some cases corporate policies require that planned and scheduled audits be performed to verify all aspects of environmental compliance and to determine effective implementation of the environmental management program. An example of this can be found in the definition of auditing as provided by U. S. Environmental Protection Agency (EPA) Policy Statement on Environmental Auditing. It defines environmental auditing as follows:
"Environmental auditing is a systematic, documented, periodic and objective review
by regulated entities of facility operations and practices related to meeting
environmental requirements. Audits can be designed to accomplish any or all of
the following: verify compliance with environmental requirements, evaluate the
effectiveness of environmental management systems already in place, or assess risks
from regulated and unregulated materials and practices.
Auditing serves as a quality assurance check to help improve the effectiveness of
basic environmental management by verifying that management practices are in
place, functioning and adequate. ''
Many specifications further emphasize that the audit be performed to written procedures or checklists (to provide later documentation) by personnel who do not have direct responsibility for performing the activities being audited. The results of such audits are generally required to be documented, reported to, and reviewed by, responsible management. Follow-up action will be taken where indicated. The responsible organization can then take follow-up action as needed.
An effective auditing program is a useful tool for improving environmental compliance. If developed properly, the program will point out areas of weakness and areas of potential problems. An auditing program will also identify
environmental compliance activities that meet or exceed expectations.
At the Pacific Northwest Laboratory(PNL), Environmental Audits used to consist of nontechnical auditors auditing to findings published in General Accounting Office reports. Today's practice of deploying a composite team of technical specialists and nontechncial auditors to audit to specific environmental programmatic requirements provides, we believe, a significant improvement.
国际和国家的标准, 而且在一些情形企业的政策需要那计划了的和预定的稽核是运行到查证所有的环境服从的方面和决定环境管理的有效落实计画。这的一例子能在环境的收支检查上的U. S. 环保署(环保署) 政策陈述旁边的依照提供的收支检查的定义中被发现。它依下列各项定义环境的收支检查:
"环境的收支检查是有系统,证明, 周期的和目检讨
被管理设备行动的实体和练习相关的到会议
环境的需求。稽核能是设计完成任何的或所有
下列各项: 查证符合环境的需求作法, 评估那
已经在地方的环境管理制度的效力, 或估定危险
从管理和紊乱的材料和练习。
收支检查服务当做教育学程认证检查到帮忙改善效力
基本环境的管理藉由查证管理实务是在
地方, 动作和适当的。''
多数规格更远的强调那稽核是运行到书面的程序或者人员的检查表( 提供更迟的文件) 做不有直接的对表演的$$1责任活动在稽查。如此的稽核的结果通常是必需的是证明, 报告到, 和检讨被, 有责任的管理。跟进行动将会被采取哪里指出。然后有责任的组织能拿依照需要的跟进行动。
一个有效的收支检查计画是改良环境的服从的一个有用的工具。如果发展适当地, 计画意志点外面的弱点区域和区域潜能问题。一个收支检查计画也意志监定环境的服从活动哪一会或超过期待。
在太平洋西北实验室(PNL), 环境的稽核过去一直有对调查结果的非技术上审计官收支检查出版在审计处报告。部署的今天练习一合成物队技术上专家和nontechncial 审计官到稽核到特性环境的标题音乐的需求提供，我们相信, 重要的进步。
CREATING AN AUDIT PROGRAM: WHY AUDIT
In the "Environmental Audit Program Design Guidelines for Federal Agencies,” (EPA/130/4-S9/001) the audit objectives are given:
"The goal of environmental management is to reduce environmental pollution and
minimize r isks associated with a facility’s production, operations and maintenance.
An environmental management program oversees the environmental functions
within an agency, generally providing guidance and technical support throughout
the entire organization. An environmental audit program is a critical component of
nn agency's ongoing environmental management program. Auditing increasingly, is
being used as a systematic method for verifying compliance with applicable statutes
and regulation, evaluating the effectiveness of environmental management systems
already in place, and identifying unregulated risks
present at a facility. In essence,
environmental auditing provides the data for a facility, or agency to prepare a
"report card" to ensure that the goals and objectives of their ongoing environmental
program are achieved.
The Environmental Protection Agency (EPA) defines environmental auditing as a
systematic, documented, periodic and objective review of facility operations and
practices related to meeting environmental requirements. ''
The May 1984 guidance document, For Preparation of Combined Work/Quality Assurance Project Plans for Environmental Monitoring (OWRS QA-1),prepared by the EPA's Office of Water Regulations and Standards, requires in Section II that the Plan include a section addressing "Performance and System Audits." It states in part. "To the extent possible, these audits should be conducted by individuals who are not directly involved in the measurement
process ....A Work/QA Project Plan should specify who will conduct the audit. what protocol will be used, what the acceptance criteria will be and to whom the audit reports will go."
This is elaborated upon in the Appendix to the EPA’s "Elements of Effective Environmental Auditing Programs," as follows:
?Explicit top management support for environmental auditing and commitment to follow-up on audit findings.
?An environmental audit team separate from and independent of the persons and activities to be audited.
?Adequate team staffing and training.
?Explicit audit program objectives, scope, resources and frequency.
? A process which collects, analyzes, interprets and documents information sufficient to achieve audit objectives.
? A process which includes specific procedures to promptly prepare candid, clear and appropriate written reports on audit findings, corrective actions, and schedules for implementation.
? A process which includes quality assurance procedures to ensure the accuracy and thoroughness of environmental audits.
Generally, the document authorizing work (i.e., a Statement of Work, or Contract) will specify, whether an audit program must be effected by the responsible organization. Assuming this to be the case, why do we audit? Here again, the guidance document identifies three purposes for performing audits:
?to determine if a particular group has the capability to conduct the monitoring before the project is initiated
?to verify that the QA Project Plan and associated "SOPs" are being implemented
?to detect and define problems so that immediate corrective action can begin. Perhaps on a less positive although valid note are additional reasons for performing audits:
?the 1986 decision by the. EPA to include Environmental Auditing provisions in enforcement settlements
?the litigious nature of our society.
The prevalent theme of the purpose statements above is one of continuous improvement and recurrence prevention. Audits are a management tool for improvement of the program.
AUDIT STANDARDS AND GUIDANCE
This chapter presents process or qualification standards for conducting audits. These documents are relatively short and provide the user with essential information for designing an audit program, preparing for an audit, or evaluating auditors.
The strength of these documents is that they provide information that is brief and easy-to-use. These documents can be used as planning checklists. The limitation of these documents is that they do not provide extensive background information or learning tools. Because they focus on the audit process or auditor qualifications, they also do not provide information on environmental requirements (e.g., regulations). While these documents may be essential for starting up an audit program, or understanding the components of an audit program, those looking for more in-depth understanding of auditing may need to seek additional materials or training to supplement this information.
This document provides the required qualifications for an air compliance auditor for small businesses in New Jersey. Qualifications include professional experience, education, and specialized seminars related to air compliance auditing. These qualifications can be used to evaluate businesses that are considering hiring an outside auditor to review their operations with respect to air compliance. The document also provides guidance for small businesses in selecting an
auditor, developing and negotiating contracts, and building a relationship with the auditor to assure that the needs of the small business are met. Despite its focus on New Jersey, the qualifications and the criteria are useful for any small business that needs to evaluate or select an auditor for conducting an audit against air compliance criteria.
In contrast to audit standards, which define how an audit should be conducted, audit criteria define how the small business should be, or would like to be, operating. These criteria include regulatory requirements, such as federal, state, or local laws and regulations. They also include non-regulatory criteria such as environmental management systems standards, best management practices for businesses and agriculture, green product standards, or sustainable practice standards. Note that despite being not required, many of the “beyond compliance” criteria are crucial to the safe and efficient operation of a facility. Beyond compliance criteria in areas such as energy efficiency or environmental management systems (EMS) can reduce operating costs, allow small businesses to reduce their compliance requirements, and allow small businesses to
constantly identify areas where environmental impact can be reduced. Furthermore, many businesses that generate hazardous waste are required by federal or state law to reduce the quantities of waste generated through pollution prevention. Thus, pollution prevention and EMS audit criteria provide opportunities for satisfying these requirements.
这一个章节礼物处理或资格引导的标准稽核。这些文件是相对地短而且提供必要的数据给使用者为设计稽核计画, 准备一稽核, 或评估审计官。这些文件的力量是他们提供数据哪一是摘要和简单易用。这些文件当做计划检查表能被用。这些文件的限制是他们做不提供广泛的背景数据或学问工具。因为他们在稽核上的焦点程序或审计官资格, 他们也做不提供关于环境的需求资讯.(举例来说, 规则) 这些文件可能是必要的对出发在稽核上面计画, 或理解成份一稽核计画, 正在找寻更多深入的人理解收支检查可能需要到找寻另外的材料或训练到补充物这数据。
这份文件提供那必需的资格为一空气服从为新泽西州的小商店的审计官。资格包括专业人士经验，教育, 和特殊化研究会相关的到空气服从收支检查。这些资格能用来评估正在考虑的商店雇用一外面审计官用尊敬检讨他们的操作到空气服从。文件也在选择一个审计官方面提供指导给小的商店, 发展中的和谈判契约, 和建筑物和
审计官的关系保证那需要小生意是遇见。尽管在新泽西州、资格和标准上的它的焦点对任何的小生意是有用的哪一需要评估或选择引导的一个审计官一稽核反对空气服从标准。
与稽查标准, 定义相反如何一稽核应该是引导, 稽核标准定义小的生意应该是如何, 或想要是,操作。这些标准包括管制的需求, 像是联邦的, 州, 或地方法律和规则。他们也包括非管制的标准，像是环境的管理制度标准, 最好为商店和农业，绿色的产品标准或足以支撑的练习标准的管理实务。不在乎不注意那必需的, 多数那" 超过服从" 标准是决定性的到那保险箱和设备的有效率的操作。超过服从标准在区域如此的当做能源效率或环境的管理制度(EMS) 能减少操作费用, 让小的商店减少他们的服从需求, 而且让小的商店到不变地监定区域哪里环境的冲击能是减少。此外, 产生有害废物的多数商店是必需的被联邦的或者州法律减少量废物产生过污染预防。因此，污染预防和EMS 稽核标准提供机会给满意的这些需求。
AUDIT TOOLS
Audit tools are used to support or implement an audit program. Tools may include audit checklistsorprotocols that
present audit criteria in a format that allows easier use by the auditor. Tools may alsoinclude audit finding ranking systems, compliance assistance documents or software, or any other material that the auditor would use during the audit process, not described in the other chapters.
Organizational Placement
Independence is one of the primary considerations to be given to any organization whose charter encompasses an audit function. The organizational nucleus of environmental auditors should be adequate to ensure objective and unencumbered inquiry, observation and testing. The objectivity of your environmental auditors should not be impaired bv personal relationships, financial encumbrances or other conflicts of interest that could impede free inquiry, or judgement. If the auditor is provided by an "Independent Audit Firm " this could mean the auditor is not to be a stockholder of the corporation being audited. The auditors must be free of real or perceived fears of retribution.
Typically, companies establish audit programs within a core
corporate group. In general, this group can be a function of the internal audit department, regulatory affairs department, legal, or environmental policy and compliance department.
When evaluating independence of the auditing organization, consideration should be given to audit funding. If costs for performing the audit are absorbed as overhead and included in the budget of the organizational unit responsible for the environmental audit program, then independence may be inferred.
Staffing and Training
In a report to the EPA in February 1984, Arthur D. Little, Inc. stated:
"Companies staff their environmental audit programs in a variety of ways. Most
environmental audit teams include individuals with technical expertise, knowledge
of environmental regulations, and plant experience. Several companies also include
auditing expertise, knowledge of environmental management systems, and
understanding of similar companies’hazard control programs as staffing criteria .”
SUSTAINING THE AUDIT PROGRAM
Management support is best demonstrated by written policy articulating upper management support for the audit and for compliance with all applicable requirements, including the organization's corporate policies and permit requirements as well as pertinent federal, state, and local statutes and regulations.
Management support for the auditing program may be further amplified by an explicit. written commitment to follow up on audit findings as to correct identified problems and preclude their recurrence.
Documenting Benefits
Environmental auditing includes a variety of compliance