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Similar to 2015-07-22 Why is an Environmental Audit Important
Similar to 2015-07-22 Why is an Environmental Audit Important (20)
2015-07-22 Why is an Environmental Audit Important
- 1. Why is an Environmental Audit Important to You? Ed Callahan
- 2. Agenda • Why perform an environmental audit? • Process of performing an audit. • What things need to be addressed during audit? • What to do after the audit is completed?
- 3. • To determine compliance status Why Perform an Environmental Audit?
- 4. Why Perform an Environmental Audit? • Avoidance of regulatory violations and monetary fines
- 5. Why Perform an Environmental Audit? • Preventative Maintenance
- 6. Why Perform an Environmental Audit? • Complex Regulations
- 7. Why Perform an Environmental Audit? • Environmental compliance is given a low priority • Complacency
- 8. Why Perform an Environmental Audit? • Good business practice
- 9. Why Perform an Environmental Audit? • Reduce major risk
- 10. Why Perform an Environmental Audit? • Peace of mind
- 11. When Should you Perform an Environmental Audit? • Changes have occurred (internal or external) – Processes – Chemicals – Personnel – Regulations • Events have occurred – Purchased a new facility – Opening a new facility – Facility or company has received a violation
- 12. When Should you Perform an Environmental Audit? • Change in personnel
- 13. When Should you Perform an Environmental Audit? • Violations – At your facility or sister facility
- 14. When Should you Perform an Environmental Audit? • As matter of routine
- 15. Elements of a Good System • Audit standards • Satisfy your individual needs • Detailed, but functional and understandable • Confirm what you are doing correctly • Provide solutions to problem areas
- 16. Elements of a Good System • Compliance Calendar – Reminder System • Good File Organization – Documentation of Methodologies • Good Housekeeping • Transferable Understanding of System – Duplicity of Knowledge
- 17. Process of Performing an Environmental Audit • Preparation • Site Walk / Inspection (Floor Practices) • Records & Data Review (Paperwork) • Findings, Actions Required, and Priorities
- 18. Preparation • Attorney-Client privilege • www.epa.gov/echo/ • Any industry-specific or area-specific rules • Audit checklist (regulations) • Create a list of permits and plans to be reviewed • Know the safety requirements • Pre-Audit questionnaire
- 19. Site Walk / Inspection • Try to tour operations in the sequence of the process (not required)
- 20. Site Walk / Inspection • Think and ask questions
- 21. Site Walk / Inspection • Note information on site/facility map
- 22. Site Walk / Inspection • Look everywhere: roof, outfalls, maintenance rooms, basement, etc… • Note “Floor Practices”
- 23. Floor Practices • Labeled drums and secured lids • Pressure drop readings • Working communication device • Permit requirements (e.g. closed doors on paint booth; pH of the wastewater effluent) • Visible emissions
- 24. Records & Data Review • Reports • Plans • Applications • Safety Data Sheets (SDSs) • Recordkeeping and Inspection Documentation • Corrective Action Documentation • Support Documentation • Training Records
- 25. Records & Data Review • Manifests • Waste Characterization Information • Lab Results • Regulatory Agency Correspondence • Purchase Records • Proof of Submittals • Old Files ??? • Documenting Non-Issues
- 26. Paperwork and Floor Practices
- 27. What Things Need to be Reviewed During Audit? • Air – Are they fulfilling the permit requirements? – Look at all permitted equipment and processes (air emissions inventory) – Look at equipment and processes that are not permitted. Should they be permitted? – Are all reports being submitted on-time and correctly?
- 28. What Things Need to be Reviewed During Audit? • Air – Are all plans developed that are required in the permit (CAM, ERP, OM&M, etc.)? Are they following and updating plans as necessary? – Is record keeping being completed as required? – Review SDS’s of any coatings, paints, etc. – Inspect the roof and look at all stacks
- 29. What Things Need to be Reviewed During Audit? • Air – Have stack tests been completed? – When are the permits due to be renewed? – Are there any planned expansions? – MACT?
- 30. What Things Need to be Reviewed During Audit? • Wastewater (NPDES or Industrial) – Are they fulfilling the permit requirements? – Look at all permitted discharges and processes. – Look at discharges that are not permitted. Should they be permitted? – Are all reports being submitted on-time and correctly?
- 31. What Things Need to be Reviewed During Audit? • Wastewater – Are all plans developed that are required in the permit (Slug Control Plan, etc.)? Are they following and updating plans, as necessary? – Is record keeping being completed as required? – Review the analytical results, DMR’s, etc. – When are the permits due to be renewed? – Categorical pretreatment standards
- 32. What Things Need to be Reviewed During Audit? • Storm Water – Do they have or do they need a storm water permit? – Review the Storm Water Pollution Prevention Plan (SWPPP). • Is it updated? Are they following it? Does the plan have all of the necessary elements? – Any sampling requirements?
- 33. What Things Need to be Reviewed During Audit? • Storm Water – Review all record keeping and reports – Where are spill kits located? – Look at “high risk” areas – Look at housekeeping
- 34. What Things Need to be Reviewed During Audit? • Spill Prevention, Control, and Countermeasures (SPCC) Plan – Oil Storage – Do they have or do they need a SPCC Plan? – Review the SPCC Plan. Is it updated? Are they following it? Does the plan have all of the necessary elements and fulfill requirements?
- 35. What Things Need to be Reviewed During Audit? • Spill Prevention, Control, and Countermeasures (SPCC) Plan – Oil Storage – Review all record keeping – Where are spill kits located? – Look at all oil storage areas – Look at housekeeping
- 36. What Things Need to be Reviewed During Audit? • Waste – What is their hazardous waste generator status (CESQG, SQG, LQG, or TSDF)? This will determine the requirements they must adhere to. – Tanks: “a potentially burdensome task” – Is all waste properly characterized (sludges, dust, etc.)?
- 37. What Things Need to be Reviewed During Audit? • Waste – Review all record keeping, manifests, and reports – Inspect all satellite accumulation and hazardous waste storage areas – Review Universal Waste program
- 38. What Things Need to be Reviewed During Audit? • Chemical Reporting – Tier II’s – Hazardous substances – very vague – Extremely hazardous substances (EHS’s) – For emergency planning purposes – Review submitted Tier II’s – Review SDS’s – Look for chemicals stored in large quantities – Review purchase records
- 39. What Things Need to be Reviewed During Audit? • Chemical Reporting – Form R’s (TRI) – Chemical or compound specific (EPA’s List of Lists) – Manufactured, processed, or otherwise used – Review submitted Form R’s and supporting documentation – Ask about methodology to determine if Form R’s are applicable
- 40. What Things Need to be Reviewed During Audit? • Other Compliance Issues – Compliance (not Phase I) – State-specific or local requirements – Tanks – Drinking water – Used oil – Refrigerants – Risk Management Plans / Process Safety Management
- 41. What To Do After the Audit is Completed? • Prioritize findings • Best Management Practice vs. Regulatory Requirement
- 42. What To Do After the Audit is Completed? • Self-Disclosure
- 43. What To Do After the Audit is Completed? • Take Action & Correct Deficiencies!
Editor's Notes
- Hello my name is Ed Callahan and I’ll be covering the next sections of why and when should you conduct an environmental audit. This photo depicts how many companies deal with environmental compliance. But we’re here to explain why audits can be beneficial.
- So why do companies conduct environmental audits? Simply stated because it’s the best way to specifically identify which environmental regulations and issues apply to your facility, make sure you are in full compliance with all of the requirements and avoid costly and unnecessary fines.
- Think of it as preventative maintenance, like going to the doctor for a checkup taking your car in for routine maintenance. The idea is to discover and fix any problems before they become more serious and costly. If you have quality or environmental systems in place, you are already aware of the importance and value of auditing.
- When I first started in the environmental business some 30 years ago, environmental audits were uncommon, mainly because there were far less regulations affecting far less industries. However, that has changed dramatically. Today there are hundreds, if not thousands, of variations of environmental regulations, some federal, some state and some local. Furthermore, any 1 of thousands of combinations of chemicals, processes, disposal, storage or transportation methods, can trigger one of these regulatory requirements. Many of these regulations are very complicated, open to interpretation and can change on a regular basis. So it is very easy for a small change or misinterpretation to mislead you into, or out of, a regulation.
- To make matters worse, due to downsizing and cut backs, many times environmental compliance is given a low priority and being managed by someone who’s main job, education and background is not environmental compliance. The most common problem I see facing companies, in regards to environmental compliance, is that they have a sense of complacency and therefore have given this critical responsibility to someone who has no background and/or is already juggling too many hats. Many time the person taking over the environmental responsibilities simply follow the status quo and moves forward in ignorant bliss. Most commonly I hear something like “I know we are in good shape because we get inspected every year and there are never any major findings.” However, here’s the problem, inspectors usually specialize in particular areas, like air or waste and can miss other issues. They are human and can also become complacent in their annual inspections. I have seen this backfire many times when a new inspector or different agency comes in and cites several violations. The companies are confused as to why this was not cited in the past, but it doesn’t matter. The responsibility comes down to you and just because it was overlooked in the past is not a consideration.
- Another reason an environmental audit can be beneficial is it make good business sense. Did you know that having a good environmental system and policies in place can actually reduce your operating cost and gain you more business prospects? Environmental management systems are designed to reduce the amount of hazardous chemicals by finding greener replacements and processes. They can also reduce your waste by recycling and finding different ways to reuse waste materials. Being green isn’t just a catch phrase anymore. This trend started several decades ago when major automotive manufactures started requiring that their suppliers and vendors have environmental management systems in place to reduce waste and their overall impact to the environment. Today more and more top companies are taking this approach and giving preference to companies that have such systems in place. Why am I mentioning environmental management systems in a talk about audits? Because all good systems start with and contain ongoing provisions for auditing.
- There can also be Major Risk associated with environmental issues. Most environmental regulations were designed to ensure that companies know what their risk to the environmental are and develop plans to manage those risk and prevent major catastrophes. So besides the obvious reasons of not wanting to pay unnecessary fines and being a good corporate citizen, think of the larger picture. An accidental spill or release to the environment can possibly affect the health and well being of your employees and surrounding community. Damage the environment and cost mega dollars in clean up and restoration. Today, companies that have been hit with a hefty fine, or simply want to be proactive and reduce their risk, are implementing environmental audits as part of their regular routine.
- This last slide on why preform an environmental leads into my next segment which is when to preform an audit, and is in my opinion the most important reason, as it relates to all of the previous slides. If you are the person responsible for environmental compliance at your facility, or for multiple facilities, an environmental audit can give you the peace of mind and confidence that you are aware of and in control of your responsibility for that position. If I worked at a company and was given the responsibility of environmental compliance the first thing I would do is have an environmental audit done to give me the details of what applies, what needs to be done, when and perhaps even why. I would not take on that responsibility without an audit, After all with all of the associated risk involved with environmental issues that I have mentioned, would you want to be the responsible person if things go wrong?
- Some of the more common reasons I advise companies to do environmental audits are all related to change or events. Change can mean a change in chemicals, a change in processes, a change in management, change in regulations, etc… and an event could be something like purchasing an existing facility, opening a new facility or getting a violation from one of the agencies.
- Here are some common examples of when an audit would be a good idea; If the person handing environmental compliance changes, perhaps someone retires or leaves the company. I have seen many cases where the person taking over gets a crash course in what environmental reports and records they need to manage and, since they have never had an issue, they maintain the status quo. In this case an audit can provide several benefits, including giving the new person confirmation that they are currently in compliance and a basic understanding of the issues and requirements. Many times an audit will also provide you with a compliance calendar for recordkeeping, reporting and training and a road map of what needs to be fixed.
- Another good reason to conduct an audit would be if your facility has received a violation. For example let’s say you’ve been cited for improperly handling hazardous waste, now would be a really good time for a complete environmental audit to review all of your potential issues, such as air, chemical reporting, water discharges, etc... Mainly because you are now on their radar and there will be follow up. In fact, if you can find a problem through an audit, before the inspectors do, then you can fix it or use Self-Disclosure to greatly reduce any fines. I’ll talk more about self-disclosure later. This also shows the agency that you are being proactive in correcting any other potential issues. Here is one most people miss; If a sister company has received a violation, you may want to audit your facility. In some cases an issue at one facility can be systemic throughout the organization. And if the same issue is discovered at another facility you can be labeled as willfully knowing, which can increase your fines exponentially.
- Finally another good reason to audit could be that it’s been awhile since your last audit. This goes back to an earlier point, things change. And although you may have been diligent on updating changes within your organization, the regulations themselves may have changed. Depending on your chemicals, materials, processes and exposure to potential environmental regulations we recommend that you do an environmental audit every 1-5 years. Companies with a high risk or exposure and limited support should audit every 1-2 years and those with little risk or greater support can probably get away with every 5 years.
- Before I pass you back to Tom Anderson, I want to make an important point. Unless you are doing an environmental audit as part of an ISO14001 or process safety management plan requirement, or have some corporate mandated system, there are really no universal standards for how environmental audits are conducted, and what detail is included in the reports. I have seen environmental audits that were simply checklist of compliance and non-compliance issues, to highly detailed documents that are confusing and would overwhelm most people. I saw one audit report that actually included the full regulations for each issue. I guess they thought that making the report bulker would help justify the cost in their client’s eyes. In fact the opposite is true. To get the most out of your audit your report it should be laid out by regulation and include some regulatory references, but also have language that non-regulatory people can understand. Due to the varying nature of audits, be prepared to discuss why you are doing an audit and what you expect in the report. A good audit report will not only detail deficiencies but also prioritize them and provide instructions on how to fix them. The report should also confirm what you are doing right. Some of the deficiencies can usually be fixed internally by updating plans, implementing inspections and reports and perhaps re-training the responsible parties. Other issues may require additional outside expertise.
- Once the walkthrough is complete, we like to sit down with management to review findings and discuss possible issues. We also prioritize high risk issues and lay out paths to solutions. This is called the draft stage and may require further investigation, and information gathering to make a complete determination on certain regulations. Once all of the data has been gathered and final determinations have been made, a final report will be issued. It is important to know that once the final report has been issued, the clock starts ticking for programs like self disclosure. Best Management Practice vs. Regulatory Requirement – we also like to include best management practices, for things that may not be a regulatory issue, but can be managed in a better manner.
- OK lets talk a little bit about self-disclosure; The federal Environmental Protection Agency and many states have “Self-Disclosure” programs in place designed to allow companies to disclose issues discovered as part of an environmental audit and make corrective actions with reduced or eliminated civil penalties. Conducting an audit in itself does not preclude you to self-disclose. However, if your corrective actions require some type of notification to the agency, then you may as well use the program to reduce fines. Some examples could be, if you did not have a required air permit for a piece of equipment, you’ll need to file an application or modification with the agency. Once they see the application, which includes the question “is this equipment new or existing?”, or when they inspect the equipment, they can quickly deduce that you have been operating the equipment without an air permit and will forward the case to enforcement. So the process of getting back into compliance includes a notice to the agency. Therefore in this case most companies choose to use self-disclosure as a precursor to the application process. If on the other hand, the audit has identified that you are missing a Spill Prevention Control and Countermeasures plan which does not require a submission or reports to the agency, many companies choose to just have the plan developed and implemented as soon as possible.
- Ok now you have a detailed report of what environmental regulations affect your specific facility, what is being done correctly and what needs to be fixed. Many times the fixes can be done internally, but sometimes it is better to utilize outside resources for more complicated fixes, such as air permitting, self-disclosure, plan development, training, etc… Most good environmental auditing firms can also provide these follow up services and help you close gaps quickly and efficiently.
- Here is our contact information if we can provide further individual assistance and/or answer any questions you may have. We’d like to thank you again for participating in todays webinar We hope you have gained some new knowledge about the importance of environmental audits.