Prepared For An Audit?
It’s possible to add value to environmental health and safety audits.
By Jack Fearing, CPEA
Planning and conducting environmental health and safety (EHS) audits for a company’s full range of operations can be daunting. These operations may include manufacturing plants, research and development labs, distribution centers, and office complexes.
Planning must incorporate a variety of considerations, including whether to formulate the process on compliance or system based issues. Other factors include emerging legislation, costs and availability of appropriate resources, identification of customers, frequency of audits, and confidentiality.
Simply stated, a compliance based audit is driven by a specific government agency (OSHA or EPA, for example), company policies, or facility written requirements (standard operating procedures, or SOPs)—in that order. Typically, the most stringent of the three takes precedence.
A system based audit is more non-regulatory but necessary for success. This type of audit should include senior management’s support and active participation (policy statement, staff meeting agenda item, etc.), employee participation (safety committees, “off-the-job” safety efforts, and so on) inspections and audits, training, contractor management, and emergency response programs. Some of these topical areas have regulatory implications, but collectively they are considered system based programs.
Determining whether the audit program should be compliance based or system based is typically a result of a company’s philosophy and the maturity of the program. Costs and frequency of an audit are usually driven by a company’s concern for being viewed as a good corporate citizen.
Getting Started
Identifying who should be involved in the EHS audit process and receipt of the report is a good first step. (Candidates include all domestic and international facility managers, EHS professionals, business unit managers, and senior managers.) All of these levels of management have a stake in the audit, and as such, the audit should fulfill each of their needs.
For confidentiality, most EHS audits are done under attorney/client privilege, and anyone on the distribution list must have a need to see the report. This can complicate the customer list and the exchange of information. Consequently, the distribution list for the final report should be large enough to include all the stakeholders but small enough to protect the privilege.
Audits are emotional exercises in most businesses. Those who have been on the receiving end know this. To be successful, the audit should address positive programs and activities (i.e., best practices), as well as program gaps, recommendations, action items (or findings), and local attention items. Another cornerstone for success is for the final report to be a clear and accurate evaluation of the overall EHS program.
The EHS Audit Program Process
The EHS added value audit program was designed to support increased performance to the traditional audit. The added value process has three primary components: recognition of all customers; knowledge transfer before, during, and after the audit; and consistency and quality.
Knowledge transfer includes an understanding of the responsibility to facilitate the action as part of audit duties, including sharing and harvesting best practices and using the guest auditor program. The program must be committed to delivering a high quality product consistently to those involved in the process.
The EHS added value audit program is a three-phase process that takes place over several weeks. Phases include the pre-audit, the on-site, and the post-audit phases. Each phase is distinct in its activities, and each subsequent phase can be viewed as a progression. Collectively, they make up the entire audit process and depend on each other in order for the audit to be successful. (See accompanying diagram.)
Pre-Audit Phase Activities
There are several essential pre-audit activities. Some of these are typically completed in the preceding year in order to allow both the facility and the team members to schedule the time necessary to conduct the audit.
