Environmental Audit: a tool to maintain environmental compliance by far

Sumitava Dutta1, Navaneeth M.T.2 M.Tech in Environmental Engineering and Management Centre for Pollution Control & Environmental Engineering Pondicherry University Puducherry-605014 sumitava.dutta88@gmail.com1 navaneethmt@gmail.com2 Abstract:
Environmental auditing evolved rapidly over the last two decades initially in America, then in Europe and in 1990s in Asia. Environmental auditing has become a valuable tool in the management and monitoring of environmental and sustainable development programmes. Although seen primarily as a tool in commerce and industry, creative application of environmental auditing techniques can improve transparency and communication in many areas of society where there is a need for greater understanding of environmental and ecosystem interactions. This information document explains the basic background to environmental auditing and its importance in maintaining environmental compliance. It further includes the basic requirements to conduct environmental audits.

1. Introduction Environmental safety and health auditing developed in the early 1970s, largely among companies operating in environmentally serious sectors such as oils and chemicals. Since then environmental auditing has spread rapidly with a corresponding development of the approaches and techniques adopted. Several factors have manipulated this growth, e.g. industrial accidents, regulatory developments, public awareness, lawsuit etc. In general the Environmental Audit is a systematic, filed, periodic and aimed process in assessing an organizations activities and services in relation to: assessing compliance with relevant legal and internal requirements, facilitating management control of environmental practices, promoting good environmental management, maintaining reliability with the public, raising staff awareness and enforcing commitment to departmental environmental policy, exploring improvement opportunities, establishing the performance baseline for developing an Environmental Management System (EMS). 2. Types of Environmental Audit There are a range of forms of Environmental Auditing process available, but among those processes six are main: 2.1 Environmental Management Audits

Audits which are specifically designed to check and evaluate the effectiveness of environmental management systems. Sound environmental management at a site or in an operation depends upon procedures, work instructions, guidelines, specification, training programmes and monitoring systems being implemented by the employees of the organization operating on the site. If these employees are not given the right instructions, training and procedures within the system, they cannot be expected to carry out their work effectively. Thus, the first stage in auditing an operation is to check the presence, absence and functioning of the environmental management system (which could be formal or informal). This then creates a baseline against which one can check the environmental functioning of an organization more effectively and objectively. 2.2 Environmental Compliance Audits Environmental compliance (or performance) audits are specifically designed to test compliance (which covers both legal compliance and corporate compliance) to environmental policies, objectives, laws, by-laws, ordinances, regulations and standards. These types of audits will often also include more numerical testing and specific checks on. 2.3 Environmental Assessment Audit

An environmental assessment audit is a mechanism used to check that an Environmental Impact Assessment complies with the minimum legal requirements and also checks to ensure that due legal process has been followed. This particular audit is used in the world to assist in EIA quality control and to reduce unnecessary costs and inconvenience should the EIA be called against. 2.4 Waste Audits Waste audits are environmental audits which specifically look at the waste management component of an operation or site. In such audits, the various aspects of waste management would be reviewed and the methods, procedures and systems checked and verified. In cases where site management are loath to undertake full site environmental audits, it is often easier to motivate for a specialized waste audit because the results of this will often more readily generate data and actions which can save money. 2.5 Environmental Due Diligence Audits Environmental due diligence audits are described in different ways but are essentially audits which look at the actual and potential environmental liabilities of a site or operation. They are most commonly carried out as a precursor to the purchase of property which has been or is likely to be used for industrial or commercial purposes. Often, they form a part of a wider financial due diligence audit which looks at the various business risks associated with the purchase of property. The kind of issues that can emerge from environmental due diligence audits include past dumping or burying of hazardous waste which may result in pollutants contaminating the groundwater. In such circumstances, the owner of the land where the waste was buried could be held liable for the cleanup costs. It is important, when purchasing property, to ensure that the new owner is not taking over someone elses hidden environmental liabilities.

A supplier audit is an audit carried out by a client to test the environmental compliance of a contractor or supplier. It should be an audit using the environmental conditions included in the contract document. In the absence of any specific conditions, it could be an audit of the suppliers environmental management system with special reference to the clients business. It is often said that in any organization, ones contractors are the weakest link in the chain of operation. This is not necessarily a reflection on the quality of the contractors service but acknowledgement of the fact that the contractor will not necessarily have the same goals and objectives as the client organization. The contractor and client will have a contractual relationship which is often based upon the supply of a specific product or service. If the client wishes a contractor to have exactly the same approach to environmental policy and systems as his own, then this needs to be included in the contract. Furthermore, the compliance with such policies and systems need to be regularly audited. Thus a supplier or contractor audit is one where the contractor is audited against the environmental requirements of the contract. 3. Audit process An audit is usually conducted by a team of people who will assemble factual information prior to and during a site visit, analyze the facts and compare them with the criteria for the audit, draw conclusions and report their findings. These steps are usually conducted within some kind of formal structure (an audit protocol) such that the process can be repeated reliably at other facilities and quality can be maintained. To ensure that an audit is effective, a number of key steps must be included and an environmental audit is typically undertaken in three phases: 3.1 Pre-Audit Activities Pre-audit steps include the administrative issues associated with planning the audit, selecting the personnel for the audit team (often from different parts of the company or from a specialized unit), preparing the audit protocol used by the organization and obtaining background information about the facility. If

2.6 Supplier Audits

auditing is new, the need for education of those involved in the audit process (the auditors or those being audited) should not be underestimated. So the stages involved in preaudit activities- 1. Define objectives, 2. Define scope, 3. Choose audit criteria, 4. Select the audit team members, 5. Develop audit plan and protocols, 6. Inform the facility(s), 7. Review background information. 3.2 On-Site Audit Activities As a first step, it is necessary to develop an understanding of the controls that are in place or are thought to be in place. These will include assessing formal procedures and practices; record keeping and monitoring; inspection and maintenance programmes and physical controls for containing leaks. The audit team gathers information on the various controls by observation, interviewing staff and the use of detailed questionnaires. Evaluating the strengths and weaknesses of internal controls provides the rationale for conducting subsequent audit steps. Auditors will look for indicators such as clearly defined responsibilities, competence of personnel, appropriate documentation and records and systems of authorization. It is more important to determine whether the system is effective than whether it is sophisticated. The audit team attempts to verify that the steps and controls work as intended. Evidence may be collected through inquiry (e.g., asking a plant operator what he or she would do if there were a major chemical spill), observation (e.g., watching specific activities and operations in progress) and testing (checking records to confirm compliance with regulations). All the information obtained is recorded (usually on the audit protocol document and as working papers), and a comprehensive record of the audit and the state of the facility at the time is thus produced. Where a deficiency is found, it is noted as an audit finding. The audit team integrates and evaluates the findings of the individual team members. Each finding and its significance can be discussed with the plant personnel. Prior to leaving the site, the audit team will often provide a written summary of findings for the plant management, to ensure that there are no surprises in the final report.

3.3 Post-audit steps Following the onsite work, the next step is to prepare a draft report, which is reviewed by the plant management to confirm its accuracy. It is then distributed to senior management according to the requirements of the company. The other key step is to develop an action plan to tackle the deficiencies. Some companies ask for recommendations for corrective action to be included in the formal audit report. The plant will then base its plan on implementing these recommendations. Other companies require the audit report to state the facts and the deficiencies, with no reference to how they should be corrected. It is then the responsibility of the plant management to devise the means of curing the failings. 3.4 Tools and techniques used in Auditing 1. Checklists, 2. Questionnaires (Audit Protocols), 3. Questioning, 4. Observation, 5. Photographs, 6. Drill Down Sampling, 7. Research 4. Conclusion Environmental audits can add value to the management approaches and compliance being taken by companies and organizations and is a way of identifying, evaluating and managing environmental risks (known and unknown). The current focus on shifting business priorities from just a financial profit bottom line to a broader Triple Bottom Line. This means that organizations need to collect more data and evaluate performance on a wider and more diverse basis. The environmental audit assists in the process of testing performance in the environmental ring and is fast becoming an obligatory aid to business decision making. Responsibility for environmental protection and sustainable development lies with both the public and private sectors separately and/or in partnership. However public sector bodies both in central and local government have key roles and responsibilities. It is important to recognize that in public sector programmes, no less than in the private sector, environmental protection is rarely if ever pursued in isolation, or as an

absolute purpose. The aim is to secure sustainable development in an appropriate balance with economic growth. Sometimes environmental and economic benefits go hand in hand i.e. reducing waste and improving energy efficiency. But needless to say at times there are conflicts. For example a village bypass may bring welcome relief from traffic and noise but on the other hand it means running a road through a local beauty spot or through agricultural land. Thus at times green winners can mean green losers. As it has been agreed at XV ICOSAI (Cairo) conference environmental auditing is an independent external audit and includes the disclosure of environmental assets and liabilities, compliance with legislation and conventions, both national and international and such measures instituted by the audit entity to promote economy, efficiency and effectiveness. 4.1 Trends/future developments Audit programmes are becoming a standard environmental management tool and pressures for the disclosure of audit results are increasing. The utility of environmental audits vary from organization to organization. It is likely that audits will be used increasingly to: 1. Provide baseline information to enable organizations to evaluate and manage environmental change, threat and risk; 2. Form the basis for initiating and monitoring the performance of Environmental Management Systems; 3. Contribute to environmental management approaches which become integrated with environmental impact assessment and the management of predicted impacts, mitigation and monitoring measures; 4. Support the implementation and management of integrated pollution control procedures and assist in the definition of 'best practicable environmental options' (BPEO);

5. Undertake external off-site impacts which consider the broader environmental footprint of an organizations activities; and 6. Surpass environmentally approaches down the supply chain. responsible

Environmental audits have traditionally dealt with the environmental effects of industrial processes and, to a lesser extent, with resource consumption. Guided by the legislation and compliance procedures, the environment has usually been considered in terms of air land and water. Considerable conservation benefits could be achieved by enlarging the focus of auditing to include natural heritage features and objectives. This would include natural heritage legislation and by the application of audit techniques to habitats and land use, such as farm units (Edwards et al.. 1992, LEAF, 1994), forest management units, or sporting estates. Generic approaches could contribute to the development of conservation management plans. 4.2 Benefits of Environmental Auditing If environmental auditing is implemented in a constructive way there are many benefits to be derived from the process. The auditing approach described in this paper will help to: 1. Safeguard the environment 2. Verify compliance with local and national laws 3. Indicate current or potential future problems that need to be addressed 4. Assess training programmes and provide data to assist in training 5. Enable companies to build on good environmental performance, give credit where appropriate and highlight deficiencies 6. Identify potential cost savings, such as from waste minimization 7. Assist the exchange and comparison of information between different plants or subsidiary companies

8. Demonstrate company commitment to environmental protection to employees, the public and the authorities. 5. Reference 1. Cahill, L.B. (1996) Environmental Audits, 7th Edition, Government Institutes, Rockville. 2. Cahill, L.B. (2001) Environmental Health and Safety Audits, 8th Edition, Government Institutes, Rockville. 3.Cheremisinoff, P.N. and Cheremisinoff, N.P. (1993) Professional Environmental Auditors Guidebook, Noyes Publications, New Jersey.Cox, Y. (2002) A Step-by-Step Guide to Providing Access to Information, Updated July 2003, LexisNexis Butterworths, Durban. 4. Greeno, J.L., Hedstrom, G.S. and Diberto, M. (1987) Environmental Auditing: Fundamentals and Techniques, 2nd Edition, Arthur D Little Inc, Cambridge. 5. Greeno, J. L., Hedstrom, G.S. and Diberto, M. (1988) The Environmental, Health, and Safety Auditors Handbook, Arthur D Little Inc, Cambridge. 6. GRI (2002) Global Reporting Initiative 2002 Sustainability Reporting Guidelines, www.globalreporting.org 7. Harrison, L. (1995) Environmental, Health, and Safety Auditing Handbook, 2nd Edition, McGraw-Hill Inc., New York. 8. Hess, K. (1997) EH&S Auditing Made Easy A Checklist Approach for Industry, Government Institutes, Rockville.

9. Heydenrych, R. and Claassen, P. (1998) A national strategy for integrated environmental management in South Africa Discussion Document, DEAT, Pretoria. 10. ICC (1991) An ICC (International Chamber of Commerce) Guide to Effective Environmental Auditing, ICC Publication No 483, ICC Publishing, Paris. 11. Kuhre, W. L. (1995) ISO 14001 Certification Environmental Management Systems A Practical Guide for preparing Effective Environmental Management Systems, Prentice Hall PTR, Upper Saddle River. 12. CAHILL, L. B. 2007a. EHS audit guidance: Audit preparation. Environmental Quality Management, 17, 27-34. 13. CAHILL, L. B. 2007b. EHS audit guidance: On-site activities. Environmental Quality Management, 17, 3-10. 14. CAHILL, L. B. 2008. EHS audit guidance: Audit findings writing guide. Environmental Quality Management, 17, 11-23. 15. Environmental, Health and Safety Auditing Roundtable. Standards for the Performance of 50. Environmental, Health and Safety Audits. 1993. 16. Environmental, Health and Safety Auditing Roundtable. Standard for the Design and Implementation of an Environmental, Health, and Safety Audit Program. 1996.