790 Environmental Management Systems (EMS)

Step 19: Conduct Internal Audits

The primary purpose of conducting EMS audits is to find gaps or nonconformances and make improvements. Regardless, there are many reasons for companies to audit their environmental performance. These include:

• Benchmarking: Compare current performance to goals.
• Customer satisfaction: Understand customer and public views.
• Information: Provide decision-makers with accurate data.
• Improvement: Identify needed changes in management, operations, or design.

Audit Types

Two types of Environmental Management System (EMS) audits are conducted, each with its own purpose.

• EMS Audits: Focus on the overall Environmental Management System, not just regulatory compliance. These audits evaluate the performance of the organization in accomplishing the following:
• Key activities, and environmental aspects are identified
• Is properly maintained and updated
• Provides effective training, communication, and recordkeeping
• Supports continual improvement in environmental performance

Audit Steps

1. Pre-audit planning: Pre-audit planning includes defining the scope, the audit team, and schedule. It involves allowance for areas of concern raised by the facility, or by previous audits or inspections. It includes review of facility permits, agency reports and communications, and emergency planning.
2. On-site activities: On-site activities include the initial conference, gathering information, evaluation of findings, and the exit interview.
• Initial Conference: In the initial conference, goals for the audit are set, a facility orientation is accomplished, and areas to be reviewed are identified. Typically upper management is involved in some way during the initial stage. They may participate directly in the opening conference or they have been involved in approving the audit and identifying key concerns.
• Gathering Information: Information gathering involves interviewing key supervisory and production personnel, physically observing production practices, and reviewing appropriate records and documents. Common measures used in audits:
• Number of inspections
• Enforcement actions
• Discharge limit exceedances
• Reportable spills and releases
• Waste quantities
• Evaluation of Findings: The goal of this phase is to evaluate the current practices in order to identify any deficiencies in regulatory compliance or the company’s stated environmental performance goals. Deficiencies can be categorized as regulatory, management system, or best practice. Examples are given below:
• Regulatory: A hazardous waste storage drum is left open without a proper lid, violating the requirement in OSHA 29 CFR 1910.120(j) that containers must remain closed to prevent spills, leaks, or worker exposure.
• Management System: Training records for employees handling hazardous waste are not consistently maintained, making it difficult to verify that all required staff have been properly trained.
• Best Practice: A funnel is not being used to pour waste solvent into hazardous waste storage containers.
3. Post-audit activities: Post-audit activities concern documenting findings and suggestions for corrective action in the form of a formal report. The audit team can then follow up at a later date to assure all necessary corrective actions have been implemented and are effective. The report and follow-up should both be communicated to upper management.

Audits may take time at first, but with practice and repetition they become more efficient and provide valuable tools for continuous improvement.

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