Improving your environmental audits is an essential aspect of operations for manufacturers and other industries. There are various ways that you can achieve the ultimate audit.
In this blog, ERA would like to show you a few environmental audit best practices and how you can use them to build a world-class environmental audit.
What is an Environmental Audit?
An environmental audit is an evaluation that allows you to assess your environmental compliance. The purpose of environmental audits is to address emissions, chemical inventories and other factors that are required in environmental reports for various regulations.
The key environmental reports include:
- Annual air emissions inventory
- Tier II report
- Toxic Release Inventory (TRI)
- Department of Homeland Security (DHS) Chemicals of Interest
- Biennial hazardous waste (RCRA)
Differences Between Environmental Audits and Health and Safety Audits
Audits allow you to investigate, understand and identify the practices in your facility that could lead to noncompliance. For environmental auditing, these practices investigate emissions but for health and safety, auditing these practices includes anything that can potentially harm any of your employees.
Health and safety audits are straightforward. They are as easy as checking your fire extinguishers and entrances to hazardous areas, whereas environmental audits require more nuanced information.
Environmental management is a complex process that is difficult to understand and requires more time to compile. For example, completing VOC calculations or calculating emissions from waste is complex and varies per facility. The main challenge is compiling all the variables that will be investigated and used for reporting effectively.
What Makes a World-Class Environmental Audit?
You know that you produced a world-class environmental audit when auditors compliment you on your record-keeping. The goal of developing a good environmental audit report is to achieve accuracy and reduce the time dedicated to reporting. You can promote your current audits to world-class status by:
- Effective record-keeping
- No data silos or redundant data sets
- Accurate, standardized calculations
- Using a robust EMS software solution such as ERA’s Environmental Module
- Thinking Like an Auditor
All these steps will help you to follow environmental regulations.
Effective Record Keeping
Effective record keeping is a challenge for many manufacturers. It comes in two parts which include:
- collecting data about your factory equipment, chemical inventory, and composition
- tracking the regulations associated with each chemical and/or process in your facility.
Here are some of the most common datasets required for environmental management:
- chemical and equipment inventories
- chemical usage and storage information
- product/material compositional information
- waste generation & waste analysis
- wastewater releases and grab sample analysis
- regulatory data for each of your chemicals
Errors in compliance reports are greatly affected by the data collection and compilation methods that your facility uses. Insufficient knowledge of chemical components from vendors and typos made by people during the data entry process can be detrimental to your environmental compliance. Having a way to directly record the chemical information from vendors is a good method of fixing these entry errors before they affect calculations.
Chemical usage and storage information is important for environmental reports such as Tier II. You will need to compile this along with purchase records to ensure effective calculation for the report. However, if your method of collection is inefficient, it can be time-consuming to factor in all these variables in your data tracking and it is prone to data redundancy and spelling errors.
Another challenge that is faced in record-keeping is the assessment of chemical usage and effective waste tracking. For example, coating facilities have a difficult time measuring emissions from their purge solvent waste because they can not quantify how much of the waste is paint and how much is solvent. Human error can overestimate the concentration of the solvent in this process which would lead to inaccurate reporting.
The main environmental compliance challenge is keeping records of all the rules and regulations that are required for each chemical or process in your facility. Regulations change frequently in twelve-month periods so in addition to collecting and compiling chemical inventory and usage information, your EHS team has the extra burden of looking up regulations associated with each chemical because each chemical has its own threshold and limit. This tedious work can greatly harm your environmental audit if it is not monitored closely.
An outstanding EHS audit involves accurate emissions calculations, product usages and efficient waste emission tracking. If we revisit the example above about purge solvent tracking, the calculations involved in that process include using SDSs to define the VOCs and HAPs. This information is then used to predict emissions by either using a waste profile to deduce them or using the quantity of the waste to predict the amounts of emissions. This process alone has two different methods with four different calculation approaches depending on available information. This work can prove to be tedious for your team.
Other calculations will require you to factor in any Continuous Emissions Monitoring System (CEMS) data. Factoring in your pollution control data will add more complexity to your calculations and inaccurate audit results. If this work is conducted using a spreadsheet, the data is more prone to errors which could lead to noncompliance.
Using a software solution (ERA’s Environmental Compliance Solution)
Using a software solution can help you to build a better audit by helping you to seamlessly calculate your material usages and emissions while seamlessly integrating pollution control gadgets. ERA’s software also has a feature that notifies you when you are approaching a threshold to ensure that you stay in compliance. Directly receiving SDS and VOC information from your vendors and material vetting are also key in lessening your load.
Software such as ERA’s system will provide you with:
- Material & facility modelling
- One database, multiple outputs
- World-class environmental record-keeping with vendor information integration
- Integrated and Upkept Master Chemical and Regulatory Library
If you are a professional who values work optimization, then improving your data collection, tracking, and reporting system is a good strategy to consider.
Think Like an Auditor
After having sufficient records and efficient systems in place for your data and emissions tracking, you must walk a mile in the shoes of your auditor. This helps you tally your record-keeping skills and calculations to the requirements of the law and avoid penalties and fines.
Remember that auditors do their research before arriving. They review your inspection template, your permits, record keeping requirements and your previous reports. These are publicly accessible on EPA databases such as ECHO. Therefore, to properly think like an auditor, take time to view your own records and see where you have made errors in the past. Auditors expect you to do your homework when you prepare for the audit. This means you must have all your information ready and equip your EHS professionals to know everything they need to present to the auditor.
Advice From Auditors
Auditors have provided some quick tips for audit improvement, and these include:
- Making sure that your documents are organized in one system (permits, permit requirements, semi-annual reports, usage records and any type of record-keeping that is required under their permit).
- Staying up to date with your industry changes and regulatory updates. For example, TRI witnessed a major change with the addition of PFAS for the 2020 reporting year and chemical thresholds are updated for each reporting year.
- Always considering your unpermitted equipment. Some pollution prevention equipment updates may not be under specific permits therefore you should monitor these and properly present them in your audit.
Also, it is completely permitted to simply talk to your auditors and find out more information about cultivating the actual audit.
Overall, the importance of effective record-keeping, accurate calculations and using software is evident in the process of building the ultimate environmental audit. Thinking like an auditor is the glue that holds this whole process together and is a process that your EHS team should also spend time on. ERA can help you with all internal and external environmental audits along with providing environmental management software tools to help meet your company’s needs. Click below to receive a complimentary consulting call to see how ERA can help you build your world-class audit.
- Environmental data collection and storage - is it accessible, transparent, and trackable?
- When preparing for an audit, try to anticipate the needs of your auditor. Does this filing system or process make sense to an outsider?
- Auditors will have reviewed your permit and reporting requirements. Have all that information easily available for them right from the start.
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December 7, 2015