Environmental Audit (EA)
Origin of EA
Environmental auditing date backs, formally, to around the promulgation of the US National Environmental Protection Act (NEPA) in 1969
US regulators started with a draft report issued by the US Environmental Protection Agency which called for independent, certified third party environmental “auditors” who would visit plants, collect samples, perform analyses and report back results to government authorities. The draft report never developed beyond a draft stage but it did result in robust debate between government and the private sector
Early documentation on environmental auditing began to appear in the mid 1980s when management consulting firms began to encourage their clients to undertake environmental audits as a means of quantifying their environmental liabilities
The first publicly recognized Environmental Audit was done in South Africa in 1989 by The South African Electrical Utility. The Environmental Audit was viewed by observers as having mixed success but it did succeed in getting various other companies to begin thinking about Environmental Auditing.
The systematic examination of the interactions between any business operation and its surroundings.
Definition : International Chamber of Commerce (ICC, 1991)
Definition : Central Pollution Control Board (CPCB, 1993)
As we are dealing with environment so thats understand the meaning of definition of EA given by CPCB. Every word in the definition has a deep rooted meaning.
It is a Management Tool
An Environmental Audit is one of many environmental management tools which are used to assess, evaluate and manage environmental and sustainability issues
The audit is sometimes confused with an Environmental Impact Assessment (EIA)
An EIA is a tool used to predict, evaluate and analyse environmental impacts before a project commences, whereas an environmental audit looks at environmental performance for an existing operation or activity
EIA is done before the developmental activity whereas Audit is done after during project operation.
Refer to carefully planned, structured and organized
It is a long term evaluation and checking process and should be a repeatable process which can be readily replicated by (if necessary) different teams of people in such a way that the results are comparable and can reflect change in both a quantifiable and qualifiable manner
The base of any environmental audit is that its findings are supported by documents and verifiable information. The audit process will seek, on a sampled basis, to track past actions, activities, events, and procedures to ensure that they are carried out according to systems requirements and in the correct manner.
Document trails are vital in verifying verbal answers to questions and ensuring that persons are carrying out their duties and tasks according the correct procedures and training.
The real value of environmental audits is the fact that they are carried out, at defined intervals, and their results can illustrate improvement or change over time. It can sometimes take as long as three iterations of an audit before sustainable environmental change and improvement can be tracked clearly.
EA reflects flexibility due to the fact that different auditors have different life and professional skills and experience and they may bring different interpretations to site situations and circumstances
Having audit teams that include specialist skills and who come back annually to repeat audits, will tend to level out any variance caused by individual skills and experience.
- The essence of any environmental audit is to find out how well the environmental organisation, environmental management and environmental equipment are performing
- Each of the three components are crucial in ensuring that the organisation’s environmental performance meets the goals set in its environmental policy
- The individual functioning and the success of integration will all play a role in the degree of success or failure of the organisation’s environmental performance.
Facilitating management control of environmental practices
- Environmental practices can happen with or without direct or specific instructions
- The key to good environmental performance is to ensure that these practices happen according to procedure, guidelines, training and systems requirements
Compliance with company policies and regulatory requirements
- Traditionally thought as compliance with the law
- Compliance with corporate policies is the primary base, which will include legal compliance as a part of any organisation’s governance policies
- Greater focus upon compliance with corporate policies which should include the requirement for environmental performance to be better than the minimum legal requirement.
Principle Elements of EA
Internal Audit is an audit carried out by the organization to check its own process and progress
External Audit is an audit carried out by one organization of another organization to check its progress
Mandatory Audit is an audit carried out by an authority to check the compliance of the process with their requirements. For e.g. insurance checks, export, etc.
Voluntary Audit is an audit carried out voluntarily by an organization or an individual of another organization to improve the process and compliance of the process with the laws
Benefits of Environmental Audit
- Determines how well the process systems and pollution control systems are performing
- Identifies potential cost saving which can be increased through reduction in raw material consumption and adoption of recycle/recovery/reduction in pollution load
- Increase awareness of environmental requirements, policies and responsibilities
- Helps in understanding the technical capabilities of the environmental organisation
- Provides up-to-date environmental data for use in plant modification, emergency etc
- Provides timely warning to management on potential future problems
- Helps in safeguard environment, and assists in complying with local, regional and national laws and regulations and environmental standards
Liabilities Audit is often conducted as a prelude to gaining insurance cover and as a means of demonstrating the regulatory compliance
Compliance audit is the most common form of environmental audit that is carried out, it is a verification process whereby the facility establishes the extent to which it is complying with the environmental legislation, regulations, emission limits, etc.
Operational risk liability audit concentrate on the potential frequency and consequence of environmentally damaging activities in the various functions of the process. Compliance with regulation does not necessarily reduce liability due to operational risks
Acquisition audits/Due diligence audit assess the liabilities due to contaminated land and building remediation costs
Health and safety audits normally form part of Health, safety and Environment (HSE) audit and involve assessment of adequacy of personal protective equipments (safety, shoes, goggles, helmets, etc.), emergency preparedness and disaster management plans.
Management Audit pays considerable attention to management systems as they are a guide to how effectively and efficiently the operations runs
A corporate audit is initiated by the main Board of a parent company and is concerned with the organization structure, roles and responsibilities, policy implementation, awareness and communication. It is carried out as a reassurance to the main Board that their aims and objectives are being implemented throughout the corporate structure
Management systems audit are carried out to check the systems against the policy and standards such as ISO 14001 (International Organization for Standardization)
Policy audit is carried out to review and reassess the relevance of the policy in the light of developments (legal, technical, financial) within the organisation and outside
Issues audit is carried out to establish environmental management plan and targets
Activities audit cover auditing of selected technical and management issues
Environmental site audit examines all aspects of the facilities performance with respect to the environment. It combines most of the elements of other types of environmental assessment and when undertaken in depth involve considerable time and cost
Waste audits are of two types. The first identifies and quantifies waste streams and is a precursor to both waste minimization programmes. The second type assesses waste management practice and procedures
Product audits cover several aspects of their environmental impacts through design, manufacture, use and disposal. Such audits are pre-requisites for identifying environmentally friendly products for “Green labelling”
Cross boundary audits assess activities, which cut across departments or business units. Transport and supply chain are such examples.
Environmental Management System (EMS)
EMS Stands for Environmental Management System. It is a system that enables any organisation irrespective of its size, type & setting to:
- Manage environmental impacts arising out of its activities, product & services
- Ensures compliance to regulations
- Brings continual improvements
- Demonstrate high environmental performance to others by conforming to policy, objectives & targets
ISO 14001 is an Environment Management System (EMS) standard published by International Organization for Standardisation in year 1996 and later updated in the year 2005
It provides a highly effective, globally accepted framework for establishing and continually improving the effectiveness of environmental management
Implementation of ISO 14000 may bring with it both reductions in environmental risk and environmental costs
Tools used in Environmental Auditing
They are very useful in specialised cases where a complex range of issues and questions need to be asked to ensure that nothing is missed.
Limitations of checklists is that there is a tendency to rely too much on a checklist and not look at matters that arise beyond the contents of the checklist or secondary questions and issues that may develop as a result of other information or observations. Some additional information needs to be used in support of checklists.
Audit protocols or audit questionnaires provide the basis and structuring for most audits. They are based upon checklist questionnaires but are more complex and include more detail and sometimes logistical information and data relating to the audit and the site being audited. When developing protocols, every effort should be made to avoid generating questions that can be answered by a simple “yes” or “no”. To trigger supplementary questions, additional information not specifically asked in the question and encourage a two-way dialogue.
Questioning is one of the most crucial aspects of auditing yet from a training and awareness point of view, it is often given the least attention. Questions should be posed in a neutral, friendly manner to prevent the auditee feeling defensive or threatened by the nature and content of the questions.
The purpose is information gathering in nature and not an interrogation. The questioner must therefore be sensitive to the perspective of the auditee and avoid making the questions accusatory, judgemental or aggressive.
Observation is a disciplined activity which must be carried out in a very deliberate and controlled manner. The idea of looking at something twice is important because it is part of the process that checks that the observation is accurately noted, analysed and recorded.
Photographs are a very valuable aid in the audit process. Formal approval to bring a camera on to site for the audit must be obtained before the audit begins.
Drill down Sampling
Drill down sampling refers to the process of investigating data as far back as possible, going right back, for example, to the point where the operator read the pressure dial and wrote the reading down on a clipboard
It is necessary, on a sampled basis, to drill down to information or action source in a number of situations to check whether a system is working and that the data being generated through the system’s requirements, is actually being generated, recorded and utilised. On finding errors and faults, the size and scope of the drill down sampling increases to explore whether the problems are of an isolated nature or whether they reflect a systems breakdown.
It is useful to try and undertake some background research and investigation into the site or company to be audited. Familiarisation with the operations, products, raw materials reports, press material and newspaper articles all provides useful background information to supplement questioning sessions and help understand the operational processes.