EHS Management StrategiesProactive Management ofEnvironmental ComplianceProactive management “What are we doing wrong?How can we do things better?” “Our fancy schmancy EMS isdeveloped and implemented,and auditing is just one part ofcontinuous improvement.”PlanCheckDoFeedbackEnvironmental Auditing
EHS Management StrategiesWhat is an Environmental AuditAn objective, systematic examination of facilities, processes,procedures and practices to verify whether they comply with legalrequirements, internal policies and accepted practices.Objectives To find problems To report them expeditiously (if required) To resolve audit findings in a timely fashion by correcting their rootcauses“Audit” vs “Review”
EHS Management StrategiesOther Drivers for EnvironmentalAuditsEPA’s audit policy/state privilege laws “We may not be penalized (as much) for identifying/disclosing ourproblems as we would if the regulators found them before we did.”Federal enforcement policies “Because of our poor environmental performance, we are under anagreed order to implement an EMS, including audits. EPA istracking our every step.”Fine prevention $$$$$$ “Oh fudge, the regulators are coming! Give us an audit QUICK, sowe can find/fix our problems before they do it for us!”
EHS Management StrategiesMaking the Audit Process WorkYou need the right team.You need the right tools.The logistics are a hassle.The findings are sensitive (in come theattorneys).Companies who commit themselves to auditsmust be ready to commit themselves toimplementing effective corrective actions.
EHS Management StrategiesSample Audit FindingException-basedcompliance finding No documentation was availableof notification to the localemergency planning commission(LEPC), SERC, and local firedepartment of hazardous orextremely hazardous substancespresent at the facility at any onetime in quantities above theircorresponding thresholds. Inaddition, no documentation of TierII reporting was available.Action item .Action: Verify the facility does notincrease the use of potable orprocess water or, in any way, dilutean effluent to meet permitlimitations. Requirement: “The permittee shall notincrease the use of potable orprocess water or, in any way,attempt to dilute an effluent as apartial or complete substitute foradequate treatment to achievecompliance with the limitationscontained in this permit” (PermitNo. 22, Section A.10).
EHS Management StrategiesSample Root Causes of AuditFindings163389ProceduresEquip./Facility DesignManagementDocument Mgmt.Unaware of Applicabilityof Regulation39 Total Findings
EHS Management StrategiesSample Corrective Action PlanFindingRootCauseCorrectiveAction PlanPersonResponsibleDueDate StatusEmergency Planning and Release Reporting (CERCLA/EPCRA/SARA)SARA 311: No documentationwas available of notificationsto the local/state emergencyplanning/responsecommissions (LEPC/SERC)and local fire department ofhazardous or extremelyhazardous substancespresent at the facility inquantities above their corUnaware ofApplicabilityofRegulation;ProcedureNot WrittenorImplementedSubmit appropriatenotifications to the LEPC,SERC, and local firedepartment.Mike Stevens;ThermoRetec tosupportQ41999Completed1/10/00SARA 312: No documentationof Tier II Hazardous ChemicalInventory reporting wasavailable.Unaware ofApplicabilityofRegulation;ProcedureNot WrittenorImplementedSubmit missing Tier IIHazardous ChemicalInventory report(s).Mike Stevens;ThermoRetec tosupportQ41999Completed1/10/00These are short-termsolutions only. Long-term solutions need toaddress root cause.
EHS Management StrategiesTypes of Environmental AuditsMultimedia complianceaudits Do the facility’s practices andrecords demonstratecompliance with regulatory andpolicy requirements? Is there evidence of complianceproblems? If so, what is the rootcause?EMS audits If the system is followedexactly, will all regulatory/policyrequirements be met? Is the system being usedappropriately by employees? Are there ways toimprove/update the system?Compliance-based EMS Assessments All of the above. This is the best way to find problems AND reasons behindthem.
EHS Management StrategiesSummary of Our ServicesSupport for our clients’ audit programs Team members on their audits EMIS tools to track scheduling logistics, audit findings, correctiveactionsReviews that are completely externalAudits combined with EMS/EMISimplementationGet certified in 120 days!!!
EHS Management Strategies, LLCGreenhouse Gas SurveyLiability Review and SOX ReportingManagement System Auditing / Training ISO 14001, TS 169494, OHSAS 18001, ISO 9001, ISO 2200SPCC / SWPPP UpdatesRCRA / DOT TrainingAir & Water Reporting / PermittingOHSA Auditing & Program DevelopmentBehavior Based Safety ProgramsEHS Management Strategies