Since the early 1970’s, private industries have recognized the benefits of conducting environmental, health and safety audits at their regulated facilities. In general, the purpose of an environmental, health and safety audit is to ensure compliance with the myriad of environmental, health and safety regulations that have been promulgated by the Occupational Health and Safety Administration (OSHA), the Environmental Protection Agency (EPA), the Nuclear Regulatory Commission (NRC), and many other federal, state and local agencies. In addition, contemporary audits include the implementation of environmental health and safety management systems such as ISO 14001 and OHSAS 18001 and adherence to corporate standards or guidelines. In order for an environmental, health and safety audit to be successful, the author offers the following tips:
- A lead auditor must be assigned. This person will have the primary responsibility for assembling the audit team, defining the scope of the audit, preparing the agenda and audit plan, reviewing the draft report, and following up with any required corrective actions upon completion of the audit.
- A primary site contact will need to be assigned. In most cases, this contact will be an environmental, health and safety manager or a person with similar responsibilities. This person should have access to all important environmental, health and safety records and permits, and should have unimpeded access to every physical area of the facility. In addition, verify that the primary site contact communicates with the highest ranking member of management at the site about the audit and its schedule. Nothing causes more of an uproar than conducting an environmental, health and safety audit at a facility where the senior management team is unaware of its occurrence. Of course, if your company has a policy that “surprise audits” are acceptable then that’s a different story.
- Pre-planning for an environmental, health and safety audit is as important as the audit itself. Much of the success of an environmental, health and safety audit program depends upon careful planning. At least two weeks prior to the on-site activities, the lead auditor should prepare and distribute an agenda to all involved personnel, including the site contact.
- Provide a list of requested documents and programs to the site contact. Copies of these documents should be received by the audit team well in advance of the on-site activities. Important documents to be included on this list are regulatory permits such as air permits, wastewater permits, radioactive materials licenses, storm water permits, etc. Written programs and associated training materials for regulatory programs such as hazard communication, chemical hygiene, respiratory protection, bloodborne pathogens, and hazardous waste management. If you are uncertain if any of these programs apply to a given facility, go ahead and include it on the list and provide the respondent with the “not applicable” option. For larger facilities, having a site map may also be helpful.
- Review written documents. The amount of time that you will have on-site will generally be limited to one week or less. For larger facilities you must use your on-site time wisely.