Environmental

AUDIT PROCESS
 Preparing the Audit
* Audits typically include:
* Document review,
* Site reconnaissance,
* Interviews,
* Records review.
* In any type of audit, the auditor will
compare evidence to criteria, and develop
findings.
Key EMS Written Information

Policy
Objectives &
Targets
EMS Procedures

Operating Procedures

Environmental Records
 Working Documents
* Forms for documenting audit
evidence and findings
* Procedures and checklists for
evaluating EMS elements
* Checklist should
* provide focus
* act as a memory jogger
* be auditor specific
* Checklist should NOT
* have exact questions
* suggest yes/no inquiries
* be totally generic
Conducting the
Audit
 Opening Meeting

* Introduce members of the audit team

* Review scope, objectives and audit
plan
* Discuss which personnel will be
involved
* Agree on timetable
* Provide summary of methods to be
used
* Establish communication links
between audit team and auditee
Opening Meeting (cont.)

* Confirm that resources and facilities

needed by the audit team are
available
* Discuss date and time of closing
meeting
* Promote active participation by
auditee
* Review relevant safety and
emergency procedures
 Collecting Audit Evidence
* Ask pertinent questions
* Listen to the responses
* Pursue vague answers
* Take complete notes
* Look for objective evidence
- “show me”
* Consult with your team leader
Specific Evidence to Look For
* Consistency between identified aspects and
observed aspects,
* How activities match procedures,
* Employee awareness of relevant EMS
elements,
* Addressing non-conformances through the
corrective action process,
* Whether the system is effective and adequate,
* Top management commitment to the EMS.
Conducting Interviews
 How to Interview
* Attitude of the auditor,
* Purpose of the interview,
* Types of questions; open, closed, leading,
antagonistic, vague.
 Typical Questions of any Employee:

* What does the environmental policy mean to you?

* What is the EMS?
* What do you do if someone is not following
procedures?
* What do you do in case of a emergency?
* What kind of environmental training have you received?
* How do you communicate environmental concerns or
ideas?
* What do you do if someone from outside asks you
environmentally-related questions?
 Typical Questions of Critical
Operations
* What significant aspects and impacts apply to your job?
* How do you know what to do? (Ask for procedures and
operating criteria).
* What specific training have you received?
* What are the objectives and targets associated with your
job?
* Do you have any responsibility for monitoring and
measurement ?
* What records do you keep?
 Categories of Interviewees:
* Plant management
* Management representatives
* Department managers
* Document control and record departments
* Research and development
* Engineering
* Operations employees (plant, administration)
* Human resources and training
* Contractor management and purchasing
* Security
Examining Documents
and Records
 Documents and Records
* Say what you do - procedures
* Do what you say,
* “Record” it (paper or electronic records)
* Must be:
* relevant to EMS (link to aspects),
* Usable and appropriate,
* Controlled,
* Reviewed and revised as “continual improvement”.
 What to Look for in
Documentation
* Does the documented system conform with the standard?
* Do the procedures describe what’s happening?
* Is the documentation controlled?
* Are all employees informed?
* Are relevant procedures followed, by everyone, all the
time?
* Is there objective evidence that the procedures are being
followed?
Documentation Hierarchy
•Level I = Upper Level “Road Map”- Policy
•Level II = EMS Procedures
•Level III = Work Instructions, Reference
documents, Regulations, etc. Records - Verify
the system (not “controlled”)
 Typical Documents and Records
to Review (by EMS Element)
Aspects Procedures
Aspects list
Significance determination information
Significant aspects/impacts list

Legal and Other Requirements

Listings of applicable legal and other requirements
Appropriate instructions for compliance
Permits, manifests, etc.
Typical Documents and Records
to Review (by EMS Element)
Objectives and Targets and Environmental
Management Programs
Minutes/notes of objective and target development
List of objectives and targets
Related action plans

Structure and Responsibility

Job descriptions
Organizational charts
Typical Documents and Records
to Review (by EMS Element)
Training Awareness and Competence
Training needs listings/matrix
Manuals, course materials
Sign-in sheets
Test records, certificate copies, etc.

Communication
Specific work instructions
Records of communication and correspondence
Typical Documents and Records
to Review (by EMS Element)
Document Control
Documents, procedures, and manuals

Operational Control
Critical operations/aspects listing/matrix
Specific work instructions
Environmental issues within work instructions
Contractor policies, work orders, etc.
Supplier requirements
Typical Documents and Records
to Review (by EMS Element)
Emergency Preparedness and Response
Emergency plans and protocols
Practice and drill results

Monitoring and Measurement

Objectives and target action plans
Specific procedures and work instructions
Records of monitoring and measurement data
Typical Documents and Records
to Review (by EMS Element)
Nonconformance, Corrective and Preventive
Action
Corrective action reports
Evidence of discussion and follow-up (meeting
notes, etc.)
Records
Monitoring records
Permits
Manifests
Correspondence
Typical Documents and Records
to Review (by EMS Element)
EMS Audit
Specific audit procedures, checklists, forms
EMS audit notes and working documents
EMS audit reports

Management Review
Meeting agendas and attendance
Meeting minutes and action items
Evidence of follow-up actions, reports, etc.
 Audit Findings

Review all audit evidence to

determine where EMS does not
conform to EMS audit criteria
(nonconformance).
 Non-Conformance vs. Non-
Compliance
* A deficiency in the EMS is a non-
conformance
* A non-compliance is a problem with
respect to regulatory requirements
* An EMS may have regulatory non-
compliance but no system non-
conformance, and vice versa.
 Types of EMS
Nonconformance
* Major –EMS does not conform to
requirements, may jeopardize certification
* Minor – deficiency in implementation of the
EMS that should be corrected by next audit cycle,
continued deficiency may jeopardize certification
* Observation – suggested, optional
improvement, no risk to certification
 What to do about a
nonconformance
• Explain the nonconformance
immediately
• Record details in a clear,
concise manner
– objective, factual, thorough,
reproducible
• Support with audit evidence
• Consult with audit team leader
Closing Meeting
 Potential Topics for Closing
Meeting
* Acknowledgment of support,
* Thanks for cooperation
* Recap of audit scope, objectives, and plan,
* Review of findings,
* Any special issues or circumstances,
* Initial discussion of next visit.
 Presentation of Findings
* Present audit findings to the auditee to
achieve
* a clear understanding of findings
* acknowledgement of the factual basis of findings
* Resolve disagreements where possible
Audit Report and Next
Steps
Preparation of Audit Report
* Prepared under the direction of
lead auditor
* Distributed to parties as agreed
with client
* Addresses topics in audit plan
* Changes should be agreed upon
by all parties
 Content
* Report should
* contain the audit findings
and/or a summary of the
findings with references to
supporting evidence
* contain additional materials as
agreed upon by the lead auditor
and the client
* be reviewed and dated by the
lead auditor
 Possible Contents of Audit
Report
Audit-related information that may be included in
the audit report:
* The identification of the organization audited and
the client,
* The agreed objectives and scope of the audit,
* The agreed criteria against which the audit was
conducted.
* The period covered by the audit and the date(s)
the audit was conducted,
 Possible Contents of Audit
Report
* Identification of the auditee’s representatives
participating in the audit,
* Identification of the audit team members,
* A statement of the confidential nature of the
contents,
* The distribution list for the audit report,
* A summary of the audit process including any
obstacles encountered,
* Audit findings and conclusion.
 Document Retention
All working documents and draft
and final reports pertaining to the
audit should be retained by
agreement between client, lead
auditor and auditee and in
accordance with any applicable
requirements.
 The Next Steps
Role of EMS Auditors in Corrective Action
• EMS auditors are not required to provide
assistance in corrective action unless requested,
• Should do so only if qualified; in other words
ability to audit does not equate with ability to fix
the problems,
• EMS auditors should review corrective actions in
subsequent audits,
• EMS Auditors must look for continual
improvement.