EHS Administration, Enforcement and Inspection, Recordkeeping, Reporting

What Is an Environment, Health, and Safety (EHS) Audit?

An EHS audit is a key piece of your EHS management system, assessing your compliance with applicable Environmental Protection Agency (EPA) regulations and Occupational Safety and Health Administration (OSHA) standards to ensure that your management system performs as intended.

EHS audit

How Should You Prepare Your Facility and Staff for an EHS Audit?

To prepare your facility for an EHS audit, you need to:

  • Determine the audit scope and area of focus. This is usually prioritized based on areas of risk, past audit findings, and recent incidents or violations.
  • Assemble an internal team of auditors, drawing from your EHS management or regulatory affairs and operations management, or contract with an outside auditing service;
  • Generate checklists and protocols for your auditing team by consulting your regulatory register of the environment, health, and safety statutes and regulations that apply to your facilities;
  • Schedule the audit when auditing teams are available and facilities are operating; and
  • Notify department managers of the pending audit so they can collect all the documentation, logs, policies, practices, procedures, and records the auditors need to review.

How Should You Select Your Auditing Team in Preparation for an Audit?

You need experienced and knowledgeable professionals to perform your EHS audits. While some companies may hire an outside auditing firm to perform and manage their audits, you may want to assemble internal auditing teams.

If you use internal auditing teams – perhaps three to five-person teams drawn from your EHS or regulatory affairs and operations departments – you must confirm that all auditors are knowledgeable in all the EPA statutes and regulations and federal OSHA or state safety standards that apply to your facilities. They should also be well trained in hazard identification and capable of identifying regulatory violations. To ensure you get objective audit reports, auditing teams should not be assigned to check their own teams or departments. You want fresh ears and eyes looking at compliance who might catch an issue that day-to-day supervisors and managers might miss.

What Does Your Auditing Team Need to Do in Preparation for an Audit?

You want to ensure that your auditing team reviews previous audit reports as well as the recommended corrective actions from earlier audits. They should start with a detailed list of closed and open audit findings.

Auditing team members also may need a refresher in your facility’s compliance obligations, including the facility’s permit requirements. They need to be apprised of regulatory changes like new limits or control measures or revised training and recordkeeping requirements. They’ll also need to be well versed on your organization’s internal policies and procedures.

Your EHS management systems should include auditing and recordkeeping functions as well as your regulatory profile – the environment and safety laws and regulations that apply to all the activities, equipment, and processes in your facility. Technology can help but you should also have processes in place to ensure that your teams are reviewing regulatory changes and assessing their impacts on your facility.

What Should Auditors’ Checklists Include?

Regardless of the scope of the audit, checklists should address every requirement contained in the laws and regulations that apply to your facility. Maintaining a regulatory register, or compliance profile, will indicate which requirements – down to each subparagraph – can serve as a good starting point for the audit team.

How Often Should You Perform an EHS Audit?

The appropriate frequency and scheduling of EHS audits can be challenging. On one hand, if you perform audits too infrequently, your workers, supervisors, and managers may become complacent between audits, only ramping up their compliance efforts as the audit date approaches. On the other hand, auditing EHS compliance too frequently can leave your personnel feeling overwhelmed, unable to correct deficiencies turned up in the last audit before the next one starts.

You may want to balance periodic, formal audits with routine checks of compliance in specific areas, departments, or workflows. Some companies use both routine audits performed by internal EHS staff combined with periodic comprehensive audits performed by third-party auditors.

Not all business units need to be audited with the same frequency. For example, you may need to audit compliance at manufacturing facilities more frequently than in warehouse and logistics facilities or administrative offices. You also can evaluate the frequency needed for compliance audits based on the risk of chemical, physical, or process hazards present in each facility.

You also need to decide on the day and time for your audit. An audit scheduled for the busiest production day of the year would be disruptive and an audit performed during production shutdown would provide little value or insight.

What Should You Do with Your Audit Results?

Your auditing teams need to provide you with two end products from their auditing work: a comprehensive audit report and a detailed description of all audit findings. An audit report will boil down all that your auditors have reviewed – team or departmental documentation, written programs and procedures, and work practices along with auditors’ checklists, measurements, comments, and recommendations.

Once completed, an EHS audit may point out deficiencies in your compliance program. If your audit identifies areas where you’re not in full compliance, findings must be evaluated and corrective actions put in place where appropriate. Corrective actions should include details of the issue as well as references to the related regulatory citations. You should also have a system to track corrective actions to closure and verify that they have been completed properly. Again, software can help to streamline these processes by providing alerts for any overdue activities and visibility into the status of pending items.

The audit results also may indicate a need for higher level action. An EHS audit may point to a need to re-evaluate and update your EHS policies and procedures.

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