How to Conduct a
World Class
Environmental Audit
Presented by
Gary Vegh

To Start
 Show of hands for:
– Health & Safety Professionals?
– Environmental Professionals?
– If Health & Safety a bigger priority at your company?
– Anyone who finds Environmental more complicated?

Environmental vs. Health & Safety
 Environmental management
– Requires more time/task
– Harder to understand
– Often like “a different language”
 Fire extinguisher training is easy.
 Air emissions compliance is not.

What would you classify as a
World Class Environmental Audit?

“When auditors compliment you on
your record keeping”

Change Your Viewpoint.
Environmental = Chemical Safety

How to Re-frame
“Environmental” For Success
 And it’s simply another form of H&S
– It’s designed to keep people safe
– Key environmental reports designed for safety

Key Environmental Reports
 Annual Air Emissions Inventory
– Like your tax return
– Keeping your workers and your local population safe by tracking air quality.
 Tier II report
– For emergency responders. Profile of hazardous substances on site.
 Toxic Release Inventory (TRI)
– Materials processed at your facility. Releases to air, water & land.
 Department of Homeland Security (DHS) Chemicals of Interest
– Tracking DHS chemical list for anti-terrorism laws.
 Biennial hazardous waste (RCRA)
– Tracking hazardous waste movement from your facility

How to Approach Environmental
 Ultimate goals:
– Reduce time required for reporting
– Get back to H&S issues
– Achieve accuracy

What are Accurate Reports For?
 Government needs accurate data:
– Public’s right to know
– Regulations are not static - EPA is
mandated to revisit regulations every 5
years
– International commitments

How Accuracy Can Suffer
 Lack of time or
commitment
– Throwing out numbers
– Not necessarily accurate
– Signing officer doesn’t know
what he’s signing
 Someone is always left
holding the bag!

Systems:
Backbone of Management
“You don’t want to be the machine.
You want to own the machine”

Why Should YOU Care?
 Another show of hands:
– If you consider yourself a
“systems improvement
person”?
 Question:
– If you’re not measuring
accurately, how can you
manage effectively?

Set Yourself Up for Success
 Environmental = Chemical/Pollutant
 For proper management you need to
know:
– What chemicals are used?
– Where do those chemicals go?
 This can seem like a complex
problem…
– 5,000 questions to answer
– Where do you start?

Let’s take a look at the
typical game plan…

Lots of Disconnected Spreadsheets.
Not Good.

The Alternative

Material & Facility Modeling

Material & Facility Modeling
 Based on our 20 Years Experience
 Boils the problem down to 2 questions
1. What materials am I using?
2. What goes on in my processes?

4 Pillars for a Successful System
1. Material & Facility Modeling
2. One database, multiple outputs
3. World class environmental record
keeping
1. Accurate
2. Transparent
3. Keep data in “raw” format
4. List of applicable regulations

Flagging Chemicals

Material & Facility Modeling

Your Materials
 Track 3 critical data sets:
1. The chemical contents of materials
• CAS
• Relevant chemical properties
2. Amount purchased
3. Amount used

What’s In Your Materials?
 Few ways to determine:
– Get data direct from suppliers
– Batch determination
– Scraped from SDSs (GHS – formerly MSDS)

Material Data Management
 Revision Tracking
– Archive old records (5 years minimum)
– Spreadsheets don’t archive

Your Facility
 Map out your facility processes
 Look at each step in your manufacturing process
– Materials used
– Impacts to:
• Air
• Water
• Waste
– Recycling
– Energy

Your Processes
 Look to understand
– Source of emissions/waste
– Effects of processes
• Transfer efficiencies, emission
factors, etc.
– Mass balance
– Pollution control devices
• Stack tests

The Big Picture

What Your System Will Produce
Complete on-site
chemical inventory
Amount of
materials processed
Air, water & waste profiles

Processed
Processed

Potential Problems
 Problems if you don’t do things right
– Fines
– ECHO list (Stock market – NYC)
– More frequent Audits
– Shutdown

How to Avoid These Problems
 Maintain comprehensive records
 Respect your Auditors
– They are not the enemy
– Use them as a resource
– Understand their situation
– Provide what they need
• If you don’t have it, provide it later

Auditor’s Mindset
 Their main goal:
– Work with industry
– Make them aware of requirements
 Their favorite part of the job:
– Working with industry
– Maintaining a good working
relationship
– Enjoying the benefits for everyone
involved

Auditor’s Mindset
 REMEMBER: Your Permit is a Contract
– Essentially “Permission to emit”

Auditor’s Mindset
 Auditors WILL have done their homework before
arriving
 They will have reviewed:
– Draft inspection template
– Your permit
– Your record keeping requirements
– Your previous reports

Auditor’s Mindset
 They expect YOU to do YOUR homework
– Review your permit
– Review your records
– Ask “Here is my emissions limit, how am I tracking
that?”

Biggest Problems an Auditor Faces
 Poor record keeping
 Company’s knowledge of
– Facility
– Permit(s)
 Turnover in EH&S staff
– Business continuity

Biggest Problems an Auditor Faces
 Having to teach & explain
during inspections
 Time!
– Several inspections scheduled
– Excessive time spent means
missed inspections
– Don’t be the person that holds
them up because you’re
disorganized!

Advice from Auditors
 Look into unpermitted equipment
 Be centrally organized in a single
location
– Permits
– Permitting requirements
– Semi annual reports
– Usage records
– Any type of record keeping that’s
required under their permit

Advice from Auditors
 Be aware of your industry
changes
 Compliance is going to
become more complex
– More federal regulations
coming
– More industries affected
 Go and talk to them

In Case You Have a “Record”

How Your History Affects You
 Bad reputation = prior violations.
 Conducting more inspections on a more
frequent basis.
 BUT…. You are not treated differently

How Your History Affects You
 Auditor’s have a program to determine fine size
 Based on:
– Severity
– Duration
– Repeat violation?
– Under your control?
– Were you co-operative?
– EPA determine “adequate enforcement”

How to Clear Up Compliance Issues
 Go to their office and talk to your auditor
 Bring your permitting people or plant manager
 They will go through your permit
– Look at what violations have occurred
– Find out why they’re happening
– Help you fix it
 They will be eager to work with you

Get a New Permit
 Your permit is not written in
stone
 In certain cases:
– Consultant drafted the permit
– Too complicated to follow
– Makes compliance extremely
difficult
 Talk to auditor about making
changes

Build Business Continuity
 To ensure continuity,
auditor’s recommend:
– Centralized system
– Easy to understand
– Keeps data in raw format

Complete Internal Audits
 Advantages of doing internal audits:
– Get more efficient
– Cut costs
– Be proactive
– Make your workplace safer

Questions?