Getting an EHS audit done on your facility by a government environmental agency can be a stressful and challenging experience for any business. That’s why it can help to know what to expect during your EHS - and how you can start getting prepared.
It’s clear that the Environmental Protection Agency places a lot of emphasis on audits. In their Emergency Planning and Community Right-to-know Act (EPCRA) Audit Guidelines, they state:
“This process [auditing] is perhaps the key element to a high-quality environmental management program” (emphasis mine).
So it’s definitely in your best interest to be ready for your turn under the EHS audit microscope (hint: one of the best ways to get prepared is to do your own self EHS audit beforehand).
Of course, every audit will go a little differently based on your processes, what industry you work in, etc., but there are a few core inspections you should expect to occur during any EHS audit.
Environmental Data Management: The Proof is in the Paperwork
Any good auditor will ask to see how you handle your environmental record keeping and paperwork. It’s essential that you get your paperwork and documentation system in order if you want to pass.
Think of it this way: your environmental data management system is like the only concrete proof you have that you are in compliance. If you’re missing the paperwork to prove you completed a required report, it doesn’t matter if you actually did it or not.
And it’s not enough to just make sure you have all your paperwork complete, it also needs to be organized and stored in a professional manner. A sloppy mess of papers in your desk will not cut it.
The EPA EHS auditing protocols even list the physical features of your environmental record keeping as an important part of any audit, so get to work cleaning that space up or make life easier with an electronic environmental data management application.
When it comes to your paperwork, you can expect your auditors to examine:
- If you have MSDSs for all your hazardous materials, and if they are accessible to those employees who would come into contact with them.
- Emergency response and contingency plans.
- Documentation for any spills, accidents, or incidents, as well as official Emergency Response Notifications sent to the EPA.
- Your chemical inventory forms, to make sure your actual physical inventory matches your record keeping and to make sure you aren’t bringing in prohibited substances.
- Your copies of all required compliance reports, like the TRI Form R, Tier II reports, etc. Naturally, you’ll need to prove you actually met all your state and federal environmental requirements.
- If you’ve developed a pollution prevention plan. Some facilities could be required to have a pollution prevention plan, and others may not be, However, having one is a good idea anyways and could demonstrate you are truly committed to running a better facility.
Along with your paperwork, the auditor will also check out the physical features of your facility related to the potential generation of hazardous releases. These include places like your shop floor and chemical storage areas, as well as end-of-life related locations like treatment units, recycling units, disposal sites, and on-site surface impoundments (lagoons, ponds, etc).
As part of the physical inspection, you should expect to get questions about your sources, including what materials get used there, what sort of control devices are in place, and how effective they are. There will be a lot of scrutiny here, as it’s the most common place for spills, leaks, fugitive emissions, and emergency shutdowns to occur.
In particular, make sure that your sources that require regular tune ups, like boilers, actually did undergo the required maintenance. And make sure you have the paperwork to back your claim up.
Prepare to show off your stacks, filters, and baghouses, too. Make sure they are all in top condition and fine working order.
Putting it All Together
So it adds up to this: during your EHS audit, the auditor will be looking to make sure your actual facility matches up with your environmental records. Both should be properly maintained and everything should be in order. if you're doing your EHS management right throughout the year, this shouldn't be a problem.
Here’s 3 last tips to get you ready:
- Make sure all your required reporting is done. No matter how great your facility or your paperwork is, if you’re missing a report, you won’t pass.
- Review the relevant regulations to make sure you haven’t missed any changes or updates.
- Resolve all issues brought up during your last audit. Nothing looks worse than not responding to the feedback the EPA gives you, and it is just asking for higher fines for repeated noncompliance.
June 15, 2012