How to Conduct a World Class Environmental Audit

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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 bigge...

Environmental vs. Health & Safety
 Environmental management
– Requires more time/task
– Harder to understand
– Often like...

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
– Ke...

Key Environmental Reports
 Annual Air Emissions Inventory
– Like your tax return
– Keeping your workers and your local po...

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

What are Accurate Reports For?
 Government needs accurate data:
– Public’s right to know
– Regulations are not static - E...

How Accuracy Can Suffer
 Lack of time or
commitment
– Throwing out numbers
– Not necessarily accurate
– Signing officer d...

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 ...

Set Yourself Up for Success
 Environmental = Chemical/Pollutant
 For proper management you need to
know:
– What chemical...

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 ...

4 Pillars for a Successful System
1. Material & Facility Modeling
2. One database, multiple outputs
3. World class environ...

Flagging Chemicals

Material & Facility Modeling

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

What’s In Your Materials?
 Few ways to determine:
– Get data direct from suppliers
– Batch determination
– Scraped from S...

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
– Impac...

Your Processes
 Look to understand
– Source of emissions/waste
– Effects of processes
• Transfer efficiencies, emission
f...

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...

How to Avoid These Problems
 Maintain comprehensive records
 Respect your Auditors
– They are not the enemy
– Use them a...

Auditor’s Mindset
 Their main goal:
– Work with industry
– Make them aware of requirements
 Their favorite part of the j...

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 t...

Auditor’s Mindset
 They expect YOU to do YOUR homework
– Review your permit
– Review your records
– Ask “Here is my emiss...

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

Biggest Problems an Auditor Faces
 Having to teach & explain
during inspections
 Time!
– Several inspections scheduled
–...

Advice from Auditors
 Look into unpermitted equipment
 Be centrally organized in a single
location
– Permits
– Permittin...

Advice from Auditors
 Be aware of your industry
changes
 Compliance is going to
become more complex
– More federal regul...

In Case You Have a “Record”

How Your History Affects You
 Bad reputation = prior violations.
 Conducting more inspections on a more
frequent basis.
...

How Your History Affects You
 Auditor’s have a program to determine fine size
 Based on:
– Severity
– Duration
– Repeat ...

How to Clear Up Compliance Issues
 Go to their office and talk to your auditor
 Bring your permitting people or plant ma...

Get a New Permit
 Your permit is not written in
stone
 In certain cases:
– Consultant drafted the permit
– Too complicat...

Build Business Continuity
 To ensure continuity,
auditor’s recommend:
– Centralized system
– Easy to understand
– Keeps d...

Complete Internal Audits
 Advantages of doing internal audits:
– Get more efficient
– Cut costs
– Be proactive
– Make you...

Questions?

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