EHS Management

Minimize Your Liability with Environmental Audits

Here’s an easy checklist that shows you how to plan your environmental audit strategy and factor in the audit’s risks of exposure, its scope, its participants, and its decision-making structure.

Audit Rationale

1 Do you have any fears that your compliance program does not meet applicable federal environmental law, rules, or regulations guidelines?

2 Do you need to ensure that your company avoids any fines for noncompliance?

3 Is your company trying to avoid federal prosecution?

4 Do you need to improve the safety of the work environment?

5 Is your company in need of more cost-effective environmental management?

6 Have you received complaints about workplace safety from your workers?

7 Is there a chance that litigation will take place?

8 Are you facing conflicts within your company or with regulatory agencies over environmental compliance?

9 Do you want to pinpoint problems for upper-level management?


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Risk Avoidance

10 Have you contacted an attorney regarding the potential ramifications of conducting an audit and has attorney-client privilege been established?

11 Has your company been cited for violations prior to the audit?

12 Is upper-level management involved in the audit?

13 Will the audit be used for Securities Exchange Commission (SEC) disclosure requirements?

14 Will you use the audit to demonstrate good faith to the Environmental Protection Agency (EPA)?

Scope

15 Have you met with the environmental staff regarding the scope of the audit?

16 Have you met with upper-level management?

17 Will the audit be:

  • Site-specific?
  • Operation-specific?
  • Regulation-specific?
  • Comprehensive?

18 Will the audit identify potential future problem areas?


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Preplanning Points

19 Are the audit’s objectives and expectations clearly stated?

20 Are there budgetary constraints to consider?

21 Will a prototype be developed for use in future audits?

22 Is there an old plant site to be studied?

23 Is there a new model site to be studied?

24 Will the audit be performed by:

  • In-house staff?
  • A third-party team?

How’d You Do?

The checklists’ questions are designed to gauge both the weaknesses and the strengths of your planning strategy. So, for example, more “no” than “yes” answers may indicate general planning strategy problems.

For questions 1-9 more “no” answers may indicate that there is probably no immediate need to conduct an audit.

But for the rest of the checklist, discrete patterns of more “no” answers may call your attention to specific loopholes in your up-front planning activities. See tomorrow’s Advisor for more of the checklist to help you with team member qualifications, pre-visit issues, and decision making for your environmental audit strategy.