A presentation at the 2015 Midwest Environmental Compliance Conference, May 13-14, 2015, Overland Park, KS

1. Top 10 Tips for an Effective Audit
Program
Midwest Environmental Compliance
Conference
May 13-14, 2015

2. Agenda
• Developing an audit program
• Conducting audits
• Audit documentation
• Audit follow up
• Questions

3. Tip #1 – Management Support
• Management support is critical to an effective
audit program
– Time and resource commitment to conduct the
audit
– Financial commitment to correct findings
– Understanding of the ultimate purpose of the
audit

4. Tip #2 – Define Scope and Purpose
• What is the purpose of the audit? (WHY?)
– Verify Compliance with regulations
– Verify compliance with company policies
– Verification for higher level program such as ISO
OSHA VPP, etc
– Administrative order mandating audits
– Identify Best Practices
– Training/education

5. Tip #2 – Define Scope and Purpose
• What is the scope of the audit? (WHAT?)
– Define the content and standard that we are
auditing against
• OSHA/EPA regulations
– Comprehensive Environmental
– Comprehensive Safety
– Targeted toward a particular regulation or standard
• Company Policy
• External standard (VPP, ISO)

6. Tip # 3 – Develop Audit Protocol
• Once the scope is identified, we then need to
determine how detailed is the audit is going to
be
– 30,000 foot view
– Detailed deep dive
– There are pros and cons with each approach,
essential to understand WHY we are performing
the audit

7. Tip # 3 – Develop Audit Protocol
• Determine the questions to be asked
– If regulatory based audit, utilize the standard that
is being audited against, each point in the
regulation should be an individual item looked
into during the audit
– View company policy similar to a regulation and
focus on key points of the policy
– External standards such as VPP and ISO will have
specific protocol to use

8. Tip # 3 – Develop Audit Protocol
• Questions should be developed for each
component of the audit
– Document review
• Based on requirements for program content, training
records, etc
– Practical application
• Will be based on employee interviews
• Site tours
– Employee Perception
• Again from employee interviews, but may ask different
questions if trying to determine perception versus
compliance

9. Tip # 3 – Develop Audit Protocol
• Draft all questions to have a “Yes” answer if
the desired objective is met
• Define what it takes to obtain a “Yes” answer
– Will all answer be either Yes or No or will there be
intermediate responses i.e. Satisfactory, Needs
Refinement, Needs Improvement, etc
– Determine “verification” for each question - the
criteria that each questions will be answered
against

10. Tip # 4 – Utilize Experienced Auditors
• Key auditor characteristics
• Experience
• Technical knowledge
• Impartial
• Can be internal or external resource or a combination
of both
• Must be able to decipher what is reality and what is not

11. Tip # 4 – Utilize Experienced Auditors
• If using more than one auditor, be certain all
auditors are calibrated to ensure consistent
results
– Review audit questions in advance of the audit
– Have multiple auditors conduct the same audit so
they can calibrate their responses

12. Tip # 5 – Announced vs Unannounced
• Determine if audits will be announced or unannounced
– Announced
• Typically more efficient use of time and resources
• Scheduling ensures that all necessary personnel for the site are
present during the audit
• Allows sites time to “prepare” for the audit
– Unannounced
• More accurate determination of sites true compliance status and
organization
• May be less efficient due to facility personnel not being present
and files not being organized and readily available
• May frustrate plant management

13. Tip #6 – Develop a Game Plan
• Establish ground rules
– Handling of discovery of critical deviation
• Internal notifications
• Are external notifications required, if so, how handled
• Will audit continue
• Start of self disclosure clock
– Scheduling of employee interviews
– Will end of day recaps be held
• Conduct opening meeting outlining the scope and intent of
the audit

14. Tip #6 – Develop a Game Plan
• Begin audit with document review
– This allows you to make notes of what to look for
in the field and also specific items to ask
employees about during employee interviews
– This also allows the auditor to inform the facility
of any missing documentation so that it may be
tracked down during the remainder of the audit

15. Tip #6 – Develop a Game Plan
• Perform site tour
– Look for specific evidence that the written
programs are indeed being implemented in the
facility. Examples…
• SWPPP Inspections indicate storm drains clear and free
of debris…are they?
• SPCC inspections indicate that containment area drain
valves are closed and locked… are they?

16. Tip #6 – Develop a Game Plan
• General Comments
– Keep in mind that there is still a manufacturing
operation going on and the auditor is there as a
service to the plant
– Remember that the auditor is simply there to
gather the facts and then report the facts.
Throughout the audit do not appear shocked,
form opinions, or provide comments based on
speculation or opinions
• “It is what it is and that’s what it is”

17. Tip #7 – Employee Interviews
• Conducting Employee Interviews
– Interview should be between auditor and employee
only, unless Union contract specifies otherwise
– Ensure the employee is aware that the interview is
confidential and that there will be no consequences
for honest feedback
– Remember that employees are a very vital source of
information so feel free to expand upon a
conversation if it is pertinent to the audit scope
– Ensure you get a representative sample of employees

18. Tip #7 – Employee Interviews
• When compiling results, look for trends in
employee responses
• A disgruntled employee is not uncommon whereas 75%
of responses discussing a specific issue or concern
bears much more weight.

19. Tip # 8 – Proper Audit Documentation
• Auditor should based comments and findings
strictly on their own observations
– If it’s not documented, it is not done
• May make note to the effect that the practice appears to be
in place but documentation is lacking
• For credibility, do not take facility’s “word for it”
– All comments and findings should be factually based.
• An audit is a snap shot in time of the actual conditions that
exist
• An audit is not intended to ask the auditor their opinion of
things
• Make notes that you allow you to best describe the actual
conditions

20. Tip # 8 – Proper Audit Documentation
• There should be some understanding of how the
audit findings are to be documented in report
format before the report is written. Different
companies prefer to see the results in different
ways
• JUST THE FACTS MA’AM!
– Discussion in the body of the report and in the audit
checklist itself must remain with strictly the details
actually observed during the audit and in some cases
follow up actions taken between the on site audit and
the issuance of the report.

21. Tip # 8 – Proper Audit Documentation
• Avoid drawing conclusions or making
judgments regarding compliance with
regulations.
– For example stating “at the time of the audit, the
facility did not have documentation supporting
preventative maintenance on control devices was
being performed” is more appropriate than stating
“the facility is in violation of its air permit because
there was no documentation to show control
device maintenance was being performed.”

22. Tip # 8 – Proper Audit Documentation
• Issue a draft report for review and comment prior
to issuing a final report
– This allows the facility to review and ensure that the
auditor has properly captured what was observed
during the audit and allows any potential
discrepancies to be addressed prior to finalizing the
audit
– Draft report must clearly indicate that they are “draft”
documents.
– While you want to ensure concurrence on report
content, do not allow the facility to write the audit
report.

23. Tip # 9 – Establish Corrective Action
Plan
• It is important and in some cases required by
regulation to document corrective actions
taken to address audit findings
• Findings should be prioritized and
responsibility assigned to addressing the
finding.

24. Tip # 9 – Establish Corrective Action
Plan
• Set reasonable yet aggressive timelines for
closing out all findings.
– Do not set yourself up for failure with over aggressive
timelines, but ensure that critical items are addressed
in a timely manner
– Often times 90 – 180 days is a reasonable time frame
to target addressing administrative findings, whereas
capital improvement may take 18 months or longer to
fully compete.
• For longer timeline items provide interim measures to
demonstrate that safety is not being compromised while the
final solution is being implemented.

25. Tip # 10 – Document Corrective
Actions
• Document all action taken including intermediate steps to
address audit findings
– Meeting minutes which show discussion on audit findings
– It is best if work orders and purchase orders generated to
address findings are kept with the audit report with a clear
reference linking the finding to the work order or purchase
order.
– Training documentation, program revisions and Sop updates can
either be kept with the report or have a reference in the report
directing you to the location of the revised document
• Want to be able to show a clear paper trail that will lead
someone to the verification that the finding was addressed

26. Additional Audit Considerations
• Audits should be approached as a means to identify
deficiencies and should not be taken personally
• Be careful of “scoring” audits and how those audits
scores are interpreted and used
• It is extremely helpful for EHS personnel to take part in
audits of other facilities if possible
• Audits should be used to accentuate the positive and
not only point out the negative, often times good best
practices can be discovered by performing audits and
those practices can then be shared to improve other
operations.

27. Additional Audit Considerations
• Attorney Client Privilege – Can audit results be
protected???
– Very specific rules to be able to effectively invoke
Attorney client privilege
• In general “Privilege” applies to communication
between and attorney and client
– Question in corporations of who is the client?
• For audits
– Defined scope
– Conducted at the request of the attorney
– In anticipation of litigation

28. QUESTIONS??
Shawn Zablocki
Industrial Program Leader
Olsson Associates
szablocki@olssonassociates.com
Office 402-938-2414
Cell 402-350-7101