Environmental, health, and safety (EHS) audits: not just a tedious waste of time, although they may sometimes feel that way to managers. On the contrary—EHS audits are vital across industries for a host of reasons—one of the largest of which is regulatory compliance. Not only that, but regularly performing gap analyses and internal EHS audits can help ensure your organization is prepared for both planned and unexpected inspections—before a regulatory agency comes knocking.
Audits and gap analyses assist in passing compliance inspections from:
- Federal agencies like the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA)
- Municipal fire department
- Accreditation organizations (The Joint Commission, The International Organization for Standardization (ISO), etc.)
- Other state and local enforcement bodies like state Departments of Environmental Protection (DEP) and Conservation (DEC)
No matter the agency or regulatory body, preparedness is the top way to impress inspectors—and only by being prepared will you succeed.
EHS audits are pivotal in determining the health of your regulatory and/or safety programs. They are designed to be all-encompassing, thorough, and can be a methodical way to collect data and evaluate if your organization is complying with applicable regulations and industry standards. Audits can focus on individual sites or the organization as a whole. EHS audits may be preplanned, with an announced date—or an auditor may show up at your facility unexpectedly and require you to show evidence of compliance.
EHS audits help ensure:
- Inspection preparedness
- Operational improvement opportunities and corrective actions
- A safe work environment
- Brand reputation and competitive advantage
Ultimately, in your audits, you want to determine the standard you’re trying to meet (e.g., Personal Protective Equipment (PPE) Compliance, Fall Protection, Laboratory Standard, Bloodborne Pathogen Standard, Fire Safety), then determine if you meet its conditions. An audit will indicate if you’re aligned with the standard’s requirements or if you’re missing key components as well as point to areas where improvements are needed. This is a time to be honest with yourself and to grade your programs critically.
To accomplish this, you can pose specific questions applicable to the sort of program you’re auditing. When auditing a hazardous waste operation, for example, the following questions are routinely addressed:
- Are all waste containers labeled?
- Are incompatible waste streams physically separated?
- Does the label communicate the hazard and the chemical components of the waste?
- Are all containers closed when not actively in use?
- Are there records of waste determination for each waste stream?
These questions are asked mainly because these violations are easy for an external auditor to spot. These are sometimes referred to as “low hanging fruit.”
If your assessment reveals that any of these requirements are not being met, the program should be identified as “Not in Compliance.” This indicates that a real audit will likely fail. Internal practice audits identify which required areas are lacking and require attention. Honing in on these weak spots can help set measurable future compliance goals with informed timelines for completion. Maintaining external audit readiness over time shows that your facility is taking EHS prioritization seriously and will go a long way to real-world compliance.
EHS Audit Types: Internal and External
Audits can either be:
- Internal, wherein an organization assesses its own EHS performance.
- External, wherein a client, stakeholder, or regulatory body is evaluating and holding an organization accountable for its EHS operations
It is important to be prepared for both audit types. If a client’s audit results in substandard findings, it may dampen their desire to work with you. Plus, if a regulator gives you a low audit score, there may be larger consequences including citations and fines.
An internal audit is crucial as it provides a clear path to evaluate safety and make operational improvements if necessary. Performing internal audits will show the way for managers to boost compliance so that the organization passes its client and regulator inspections.
Typical EHS Audit Focus Areas
Given their importance and their potential consequences, EHS inspections of any sort are a major task. While the type and complexity of audits will vary based on the specifics of your operations, audits should center around a single program or operational component, such as:
- Hazardous waste management and disposal
- Indoor air quality program
- Chemical inventory management
- Lockout/Tagout
- Emergency response
EHS Audit Flows: From Start to Finish
These reviews happen in three main phases:
Pre-Audit Steps:
It’s best to prepare far in advance, before a regulatory agency comes knocking unannounced. During the prep phase, you should focus on complete inspection preparation. Focus on aligning all of your information, programs, and documentation. This effort should include:
- Determining what regulations apply to your facility.
- Are there local regulations that are more stringent than the federal ones?
- What regulations are mandatory vs. best practice?
- How do all of these rules apply to your operations?
- Reviewing the EHS management and compliance tools in place at your facility. Tool components may include:
- Hazardous waste tracking database
- A compliance calendar
- Training certifications
- Risk assessments
- Performing a gap analysis to see where EHS weaknesses lie—and craft ways to overcome them.
- Ensuring all mechanical equipment is maintained and up to date.
- Reviewing any “stains” on the facility record—as well as the mitigation measures that can “clean” them. This may include listing:
- Pollution control devices and/or waste minimization operations as well as their relevant installation/implementation dates
- Job hazard assessments and their documented hazard controls
- Past spills, their clean up reports, and their relevant waste manifest
- Employee injuries and their related incident reports, OSHA log of the incident, and a physician’s written opinion
- Regularly practicing facility-wide audits to ensure preparedness for all employees. Run through a full mock audit: Imagine yourself inside an auditor’s head! This will ensure all employees know what’s happening on audit day. Prepare employees for impromptu interviews. Practice like you perform so you can be the most prepared to succeed.
- Compiling all necessary documentation. Most EHS programs require you to have records that show compliance (e.g., training certificates, air monitoring results, risk assessments, permits, etc.). Having these items readily available will prove to any regulatory inspector that you are making efforts to stay compliant.
- Planning the auditor walkthrough. Have a plan, but ensure flexibility. Flexibility allows an auditor to drill down into areas of interest should they so choose.
Effective preparation enables productive audits; don’t skimp on pre-audit prep. Don’t cut corners in your efforts! Take steps to proactively anticipate the scope of the inspector’s questions. Pre audit preparation will result in external audit success.
Audit Steps:
Usually, external audits are not scheduled. A regulator can pop into a facility, and the staff will be expected to have all relevant documents readily available. If an audit is planned in advance, which is rare, it’s wise for the subjected organization to begin the audit day with a pre-audit meeting that involves:
- Including all employees that may be interviewed or consulted with. This may be more than just the people on the EHS team—all relevant stakeholders who in any way support EHS operations may be called upon. They may hold a variety of non-EHS roles and come from any level of the organization’s hierarchy. Potential participants include:
- The executive team
- Frontline supervisors
- Employees in separate departments
- HR
- Laboratory managers
- Non-frontline staff: Trainers, recordkeepers, and other operational staff who may not be on the front line
- Establishing the scope of the audit to ensure you provide all expected documentation, like:
- OSHA logs
- Cleaning, disinfection, and maintenance records
- Employee exposure records
- Employee training records
- Setting expectations for the audit, such as if the inspector will take photos, videos, etc.
During the walkthrough of your facility:
- Be as efficient and clutter free as possible to avoid business disruption
- Answer all questions thoughtfully and completely
- Offer personal protective equipment (PPE) to the auditor
- Photograph any area or object the auditor photographs; capture exactly what they capture
- Get copies of all audit documentation
At the closing conference:
- Review observations and notes
- Develop an action plan for operations improvement
Remember: Regulatory inspections can take 30 days or more if auditors find any non-compliance issues.
Post-Audit Steps:
Immediately after the audit:
- Perform an internal review of all the inspector’s observations
- Implement the closing conference’s action plan
- Pinpoint any areas needing further improvement
- If you received a citation, determine if you consider the judgement fair—of if you will contest the validity of the alleged violation
Remember, learning from past mistakes is the only way to move forward.
EHS Audits and Regulatory Compliance: Easier with a Partner
The whole audit lifecycle presents many individual components. This requires extensive pre-audit practice. Often, audit preparation and compliance demand a substantial portion of time and resources to do it successfully.
Working with a skilled partner may ease the burden of EHS auditing. The team at Triumvirate Environmental has been proactively and successfully helping organizations with EHS audits for over 30 years—including practice audits. We see things internal managers may not see because they are so commonplace.
We can also assist with any of the preparatory steps—including determining compliance requirements for different programs, operations, and locations. In some cases, we can even take over your EHS audit burden completely and offer robust support to help reach organizational goals.
Interested in more information? Learn more about EHS auditing.
