Environmental Protection and Management (18CV753) Sharmila A
Module -3
Environmental Audit Environmental management system audits as per ISO 19011- – Roles
and qualifications of auditors - Environmental performance indicators and their evaluation – Non
conformance – Corrective and preventive actions –compliance audits – waste audits and waste
minimization planning – Environmental statement (form V) - Due diligence audit - 8 Hours
What is an audit?
An audit is a systematic, independent and documented process for obtaining audit
evidence and evaluating it objective to determine the extent to which audit criteria are
fulfilled
What is an internal audit?
An internal quality audit is an audit that is performed by or at the direction of members
of the organization
Why audit?
Possible reasons to audit
ensure compliance with ISO 14001
ensure compliance with organization requirements
ensure compliance with regulatory requirements
ensure the QMS is effectively implemented and maintained
Auditing for improved performance
look for opportunities for improvement
look for best practices that could be applied in other areas
look for preventive action
look for outstanding
emphasis on customer satisfaction
Principles of auditing
Ethical conduct
Fair presentation
Professional care
Independence
Objectivity
Impartiality
Evaluations based on evidence
Competence
Cooperation
Trust
Three Types of Audits
External independent audits – third party
Conformity to a specific standard
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Customer audits of suppliers – second party
Conformance to customer requirements
Customer’s special interest items
Internal audits – first party
Performance to the organization’s objectives
Identification of problem areas
Finding opportunities for improvement
The Process Approach
Evolving nature of quality management
Internal focus vs. customer focus
Control vs. improvement
QA by organization
Leadership: from QA or from management
Documented procedures vs. manage processes
Alignment of business, policy and objectives
4 Phases of an audit
1) Audit preparation
Audit preparation consists of everything that is done in advance by interested
parties, such as the auditor, the lead auditor, the client, and the audit program
manager, to ensure that the audit complies with the client’s objective
The preparation stage of an audit begins with the decision to conduct the audit
Preparation ends when the audit itself begins.
2) Audit performance
The performance phase of an audit is often called the fieldwork
It is the data-gathering portion of the audit and covers the time period from arrival
at the audit location up to the exit meeting
It consists of activities including on-site audit management, meeting with the
auditee, understanding the process and system controls and verifying that these
controls work, communicating among team members, and communicating with
the auditee
3) Audit reporting
The purpose of the audit report is to communicate the results of the investigation
The report should provide correct and clear data that will be effective as a
management aid in addressing important organizational issues
The audit process may end when the report is issued by the lead auditor or after
follow-up actions are completed
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4) Audit follow-up and closure
According to ISO 19011, clause 6.6, “The audit is completed when all the
planned audit activities have been carried out, or otherwise agreed with the audit
client.”
Clause 6.7 of ISO 19011 continues by stating that verification of follow-up actions
may be part of a subsequent audit
Members in audit committee
Lead Auditor
The lead auditor is responsible for the organisation and management of the audit
and liaise with the client or the contact person in the case of an internal audit
The lead auditor is also responsible for the organisation, recruitment and
management of the audit team and ensuring that the necessary deliverables from
the audit, including the audit report, are delivered according to the agreed
timetable and plan.
Auditor
The auditor will undertake auditing tasks, alone or as a member of a team, and
must be conscious of the ethical and professional responsibilities of his task
This will include ensuring that the audit work is thorough, fair and accurate.
Technical expert
In some cases, a technical expert will be included as a part of an audit team to
assist with understanding and interpreting technical aspects of the operation or
site being audited
The technical expert does not necessarily have to be an auditor but it does help.
Audit team
Audit team must work together, under the leadership of the lead auditor, to
ensure completion within the brief and scope of the audit
Team must be mindful that their activities could disrupt the normal operations of
a site or plant and therefore must minimise the negative impact of their inquiries.
Client
The client is the individual or organisation that commissions the audit
In the case of an external audit, it may be the Chief Executive Officer of a
company or the Environmental Manager.
In the case of an internal audit, it could be the departmental head or the Audit
Manager
The client and auditee can sometimes be the same individual, depending upon
the structure and system within an organisation or company.
Roles and qualifications of auditors
Education needed to become an ISO Auditor
To become an ISO auditor, need at least a diploma, certificate or associate’s
degree from a technical college in a field related to environmental management,
systems management or quality assurance. Some employers may require
bachelor’s degree in one of the following fields
• Environmental Science
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Environmental Protection and Management (18CV753) Sharmila A
• Environmental Management
• Natural Resource Management
• Environmental Engineering
• Environmental Assessment
Who Hires ISO Auditors?
ISO auditors may be employed by or work on a contract basis for such organizations
as-
• Engineering, environmental and systems management consulting firms
• Federal, provincial/state and municipal government departments
• Utility companies
• Manufacturing firms
• Resource-based companies (agriculture, forestry, mining, oil and gas)
• Self-employment (on a consultancy basis)
TYPES OF ENVIRONMENTAL AUDITS
[These are audits which are specifically designed to check and evaluate the
effectiveness of environmental management systems.
Sound environmental management at a site or in an operation depends upon
procedures, work instructions, guidelines, specification, training programmes and
monitoring systems being implemented by the employees of the organisation
operating on the site.
If these employees are not given the right instructions, training and procedures
within the system, they cannot be expected to carry out their work effectively.
Thus, the first stage in auditing an operation is to check the presence, absence
and functioning of the environmental management system (which could be formal
or informal). This then creates a baseline against which one can check the
environmental functioning of an organisation more effectively and objectively.]
1) Environmental Compliance Audits
Environmental compliance (or performance) audits are specifically designed to
test compliance (which covers both legal compliance and corporate compliance)
to environmental policies, objectives, laws, by-laws, ordinances, regulations and
standards.
These types of audits will often also include more numerical testing and specific
checks on, for example, compliance with requirements in water and air permits
and licenses.
2) Environmental Assessment Audit
An environmental assessment audit is an instrument used to check that an
Environmental Impact Assessment complies with the minimum legal
requirements and also checks to ensure that due legal process has been
followed.
To assist in EIA quality control and to reduce unnecessary costs and
inconvenience should the EIA be appealed against.
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3) Waste Audits
Waste audits are environmental audits which specifically look at the waste
management component of an operation or site.
In such audits, the various aspects of waste management would be reviewed and
the methods, procedures and systems checked and verified.
4) Environmental Due Diligence Audits
Environmental due diligence audits are essentially audits which look at the actual
and potential environmental liabilities of a site or operation.
They are most commonly carried out as a precursor to the purchase of property
which has been or is likely to be used for industrial or commercial purposes.
The kind of issues that can emerge from environmental due diligence audits
include past dumping or burying of hazardous waste which may result in
pollutants contaminating the groundwater.
In such circumstances, the owner of the land where the waste was buried could
be held liable for the clean up costs.
It is important, when purchasing property, to ensure that the new owner is not
taking over someone else’s hidden environmental liabilities.
5) Supplier Audits
A supplier audit is an audit carried out by a client to test the environmental
compliance of a contractor or supplier.
It should be an audit using the environmental conditions included in the contract
document.
This is not necessarily a reflection on the quality of the contractor’s service but
acknowledgement of the fact that the contractor will not necessarily have the
same goals and objectives as the client organisation.
The contractor and client will have a contractual relationship which is often based
upon the supply of a specific product or service.
Thus a supplier or contractor audit is one where the contractor is audited against
the environmental requirements of the contract.
Process involved in undertaking an Environmental Audit
Scope of Audit
The scope of the audit determines exactly what will be done during the audit and
what the deliverables of the audit will be.
In the case of an EMS audit, a typical scope or set of objectives would cover:
conformance with EMS criteria; whether or not the EMS has been fully
implemented and the system maintained; areas of potential improvement for the
EMS; and effectiveness of internal management review.
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1) Planning of Audit
The effective planning and logistics of an audit is critical to ensure a successful
audit
Apart from ensuring that the appropriate staff are available to answer audit
questions, the logistics of an audit needs to be organised to prevent wasting
time.
2) Pre-Audit Meeting
A pre-audit meeting is an important prerequisite for the audit because it is the
first opportunity to meet the auditee and deal with any concerns.
It is also the opportunity to gather any documentation that the audit team can
study before arriving on site.
The audit protocol and audit plan can be handed over at this meeting and
discussed in advance of the audit itself.
The meeting also presents the opportunity to reinforce the scope and objectives
of the audit and discuss practicalities associated with the audit (e.g. access to
key staff, photographs on site, site tour, access to documentation, etc.).
3) Second pre-audit meeting (optional)
Auditees may have concerns and questions arising from the pre-audit meeting
which cannot be dealt with telephonically or by email.
This type of follow up meeting is entirely optional but may assist in bolstering
confidence in the audit process and providing support for the auditee’s efforts to
establish internal auditing systems and processes.
4) Auditor Meeting
With more complex audits, it is useful to have an auditor meeting before the audit
to allocate specific assignments to auditors and confirm details and deadlines.
The logistics of this will vary enormously.
5) Opening meeting
The opening meeting is the first activity of the on-site audit and is the opportunity
to introduce the audit team to the site staff.
6) Audit
a) Site Tour
The next part of the audit is the site tour which is designed to familiarize the
audit team with activities and operations.
b) Questioning, document review and evidence gathering
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The core work of the audit is working through the audit protocol, asking
questions, checking answers against site documentation (manuals, reports,
monitoring data, work instructions, procedures, training schedules etc.),
reviewing documentation against standards, policies and action plans and
gathering evidence to support the answers to the questions.
c) Consolidation, audit findings and review
Time must be allowed for the team to consolidate its findings and prepare the
basis for the preliminary report back to be given at the exit meeting.
d) Exit meeting
The exit meeting is run by the lead auditor and is the mechanism to feedback
broad, preliminary findings to site management and staff before the audit
team leaves the site.
e) Draft Audit report
The information gathered by the audit team is consolidated and written up as
a draft audit report.
This draft report will then be circulated to the audit team and those directly
concerned with the audit.
The purpose is to check the report for accuracy
7) Final Audit report
The final audit report is the corrected final document which contains the findings
and recommendations of the audit.
It will also form one of the bases of future audits because the information it
contains informs some of the tests and analyses that need to be performed in the
future.
8) Follow up and Action Plans
Environmental audits form part of an on-going process of continuous
improvement. They build upon information from previous audits and create a
baseline for future audits.
For this reason, follow up work in the form of analyses of recommendations and
action plans is a crucial part of an audit.
9) Next Audit
In order to promote continuous improvement it is recommended that the idea of
the next audit be discussed during the exit meeting.
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ISO 14001 NON-CONFORMANCE, CORRECTIVE AND PREVENTIVE ACTION
What is a Major Non-Conformance?
A deficiency that seriously impairs the effectiveness of the EMS
Examples
❑ An element of ISO 14001 not implemented
❑ Procedures not developed or not implemented
❑ Failure to take corrective or preventive action
❑ Several minor non-conformances
What is a Minor Non-Conformance?
A minor deficiency that does not seriously impair the effectiveness of the EMS
Examples
❑ One or a few individuals (out of many) do not use a procedure correctly
❑ Procedure needs minor changes to be effective
❑ One or a few records incomplete
What are Corrective and Preventive Actions?
Corrective action fixes the immediate problem (e.g., repair a leaking valve)
Preventive action is designed to stop the problem occurring again, or stop
problems before it happen (e.g., improved maintenance procedures)
Effective preventive actions are a key to CONTINUAL IMPROVEMENT
ISO 14001 Non-Conformance, Corrective and Preventive Action says-
The organization shall establish and maintain procedures for defining
responsibility and authority for handling and investigating nonconformance,
taking action to mitigate any impacts caused, and for initiating and completing
corrective and preventive action
ISO 14001 also says-
Any corrective and preventive action taken to eliminate the causes of actual and
potential non-conformances shall be appropriate to the magnitude of problems
and commensurate with the environmental impact encountered
Steps to Identify and Correct Non-Conformance
Identify problem through routine inspection, monitoring, audit findings, trend
analysis, employee comments, complaint, experience
Investigate problem and its underlying causes
Involve persons with first-hand knowledge of the issues, and authority to achieve
solutions
Identify best solution(s) and persons responsible for implementing them
More Steps to Identify and Correct Non-Conformance
Ensure solution is adequate for the size and nature of the problem, i.e., fix the
underlying cause(s) once and for all
Follow-up with monitoring to confirm that implemented solution is effective long-
term
Involve people throughout with sufficient influence to ‘make things happen’
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promptly
Non-Conformance Investigation Example
PROBLEM
Environmental monitoring results not submitted to government on time
Possible underlying causes
» Responsibility for reporting not clearly communicated
» Inadequate training or awareness of reporting schedule requirements
» Written procedure not available
» Insufficient supervision and checking
One More Thing from ISO 14001
The organization shall implement and record any changes in the documented
procedures resulting from corrective and preventive action
This means that procedures must be kept
up to date (i.e., maintained) to include new actions required to prevent previous
problems
Consequences of Non- Conformance
MAJOR NON-CONFORMANCE
Registration to ISO 14001 delayed until problem is corrected and re-audited
MINOR NON-CONFORMANCE
Can receive registration to ISO 14001 but must commit to fix problem within 60
days; correction will be confirmed on next audit
Concluding Thoughts
Important points to remember are
Need open communication, without fear of punishment for identifying a non-
conformance
Need somebody with authority incharge of responding to non-conformances
Need thorough investigation of symptoms and underlying causes of each non-
conformance involving knowledgeable persons and those affected by the non-
conformance
Additional points to remember are-
Need identification and implementation of lasting solutions that change the
system (i.e., the way things are done), not just the symptoms
Need follow-up to ensure the solution provides lasting improvement
Need update documented procedures to include corrective and preventive
actions
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Environmental Protection and Management (18CV753) Sharmila A
Waste minimisation
Why minimise waste?
Figure 1: Waste miminization
Preferred hierarchy of waste management options
Figure 2: Hierarchy of waste management options
Source reduction opportunities
Figure 3: Source reduction opportunities
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Factors influencing waste minimization
• Government policy and regulations
• Technological feasibility
• Economic viability
• Management commitment and support
Waste minimisation - incentives
• Reduced costs
• raw materials, energy, water
• storage and handling
• waste disposal
• health and safety
• Regulatory compliance
• Improved efficiency
• Improved corporate image
Waste minimisation - barriers
• Economic barriers
• Technical barriers
• Regulatory barriers
Waste minimisation opportunities applicable to all operations
• Use higher purity materials
• Use less toxic raw materials
• Use non-corrosive materials
• Convert from batch to continuous process
• Improve equipment inspection & maintenance
• Improve operator training
• Improve supervision
• Improve housekeeping
• Improve material tracking and inventory control
• avoid over-purchasing
• inspect deliveries before acceptance
• make frequent inventory checks
• label all containers accurately
• ensure materials with limited shelf-life are used by expiry date
• Install computer-assisted inventory control
Implementing a company waste minimisation programme
• A systematic and ongoing effort to reduce waste generation
• Must be tailored to specific company needs and practices
3 main phases
• planning and organisation
• conducting a waste audit
• implementing, monitoring and reviewing
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Phase 1: Planning and organization
• Obtain management commitment
• Establish programme task force
• Set goals and priorities
• Establish an audit team
Phase 2: Waste audit
Figure 4: Steps in waste audit
Step 1: Identify plant operations
• Inspect the site
• Identify different processes undertaken on site
• List processes and obtain as much information as possible on the process
Step 2: Define process inputs
Account for all the material flows into each individual process
• materials
• energy
• water
• Make sure all inputs are accounted for in detail
• Example: kg of raw materials, kilowatts of electricity, litres of water
Make sure figures are on same basis
Example: annual, monthly, weekly inputs
Step 3: Define process outputs
Identify and quantify all process outputs
• primary products
• co-products
• waste for re-use or recycling
• waste for disposal
Step 4: Assess material balance
To ensure that all resources are accounted for, conduct a materials balance
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assessment
Figure 5: Material balance
Typical components of a material balance
Figure : 6 Components of a material balance
Step 5: Identify opportunities for waste minimization
Using data acquired during the waste audit, make preliminary evaluation of the
potential for waste minimisation
Priorities options for implementation
Step 6: Conduct feasibility study
Conduct feasibility analysis of selected options
◦ Technical considerations
• Availability of technology
• Facility constraints including compatibility with existing operation
• Product requirements
• Operator safety and training
• Potential for health and environmental impacts
◦ Economic considerations
• Capital and operating costs
• Pay-back period
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Phase 3: Implementing, monitoring and reviewing
• Prepare Action Plan
• Identify resources
• Implement the measures
• Evaluate performance
Summary
• There are a number of good reasons for minimising waste - source reduction
comes at the top of the waste hierarchy
• Factors which influence waste minimisation include regulations, technological
feasibility, economic viability and management support
• There are both incentives and barriers; some opportunities widely applicable -
and valuable experience from demonstration projects
• Guide to implementing a company waste minimisation programme and
conducting an audit
Environmental Due Diligence (EDD)
Due diligence is relevant in all areas of business and is used to identify liabilities.
Some may be obvious, while others can be hidden.
Ex: Sometimes purchasers and funders pay unforeseen costs due to unrecognised
liabilities that have been inherited via a purchase
EDD assessment will identify the current conditions of a business or site and
determine any liabilities or non-compliance that may inherit through an
acquisition
Excellent way to understand the current environmental performance of a
potential investment and its associated environmental risks and be prepared for
anything need to deal with as part of the purchase
Gives idea on how EDD audit would work, what outcomes should be expected
and why it is important to have an audit done if looking at business or land
purchase.
How does an EDD audit work?
An audit will usually start out with meetings with key personnel within the
organisation, progressing to a site tour and inspection
For multiple sites, a representative sample will be audited while taking into
account location and on site activities.
Review of key documentation and data will take place to give an overall picture of
the potential investments environmental situation.
Audits obviously vary depending on the size of the organisation, current and
historical activities and sometimes on the industry in which the organisation
operates.
Concerns in audit - land, air and water emissions, environmental permitting
concerns, waste management, oil and chemical storage and statutory nuisances
in addition to any site or organisation specific concerns
What will an EDD report show?
Following audit, a report will be prepared.
Report will give idea of what is happening in a business or on a site by evaluating
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the current environmental risks or any legal non-conformities
Focus on three broad areas; legal compliance, barriers to growth and a
determination of clean up liabilities and costs.
Include any land or water contamination and any impending or required
permitting requirements.
If any pollution has been identified, report will conclude with an estimation of any
clean up required to return the land to its original state.
What do with EDD report?
The EDD report will show up any potential problems and some of it may need to
be dealt soon
The Environmental Damage (Prevention and Remediation) Regulations, the
‘polluter pays’ principle is set out in the law.
Its purpose is to prevent and repair any environmental damage caused by
industrial activities, regardless of the size of the company.
Many are unaware that when purchasing a new business or land, may inherit
with existing environmental issues, illegalities and clean up liabilities.
Is EDD a necessary expense?
Environmental matters are becoming increasingly important and are being more
heavily regulated with stricter laws and regulations and more severe penalties for
breaching the requirements
Poses a risk for organisations, especially if not aware of requirements.
EDD is a way of being more aware of risks so can be managed as part of wider
business strategy
EDD is also often requested by financial institutions, lenders and stakeholders -
investment is viable.
Being aware of risks means need to mitigate against it, which can be costly,
prosecution, fines and the devaluing of investment
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