EVOLUTION OF AN ENVIRONMENTAL AUDIT PROGRAM

J. H. Maday T. L. Kuusinen

October 1991 Presented at the Environmental Auditing Conference October 22-23, 1991 Seattle, Washington

Work supported by the U.S. Department of Energy under Contract DE-ACO6-76RLO 1830

Pacific Northwest Laboratory Richland, Washington 99352 DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States。Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. Evolution of an Environmental Audit Program

Joseph H. Maday, Jr. (ASQC-CQA) Technical Group Leader - Quality Verification Department and Tapio Kuusinen Senior Research Scientist Environmental Policy and Compliance Group Pacific Northwest Laboratory Richland, Washington 99352 ACKNOWLEDGEMENT This document was prepared under the direction of the U.S. Environment Protection Agency’s (EPA) Small Business Division. There were numerous reviewers from government and private organizations. Additionally, the following provided important advice and/or reference materials: * Small Business Ombudsman, Maine Department of Environmental Protection * Tennessee Small Business Assistance Program * New Jersey Department of Environmental Protection * Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA) * Iowa Waste Reduction Center, University of Northern Iowa * Florida Small Business Assistance Program The products and services included in this document were contributed for review by commercial and government sources. The project team is thankful for their timely cooperation. ABSTRACT International and national standards, and in some cases corporate policies require that planned and scheduled audits be performed to verify all aspects of environmental compliance and to determine effective implementation of the environmental management program. An example of this can be found in the definition of auditing as provided by U. S. Environmental Protection Agency (EPA) Policy Statement on Environmental Auditing. It defines environmental auditing as follows:

"Environmental auditing is a systematic, documented, periodic and objective review by regulated entities of facility operations and practices related to meeting environmental requirements. Audits can be designed to accomplish any or all of the following: verify compliance with environmental requirements, evaluate the effectiveness of environmental management systems already in place, or assess risks from regulated and unregulated materials and practices.

Auditing serves as a quality assurance check to help improve the effectiveness of basic environmental management by verifying that management practices are in place, functioning and adequate. ''

Many specifications further emphasize that the audit be performed to written procedures or checklists (to provide later documentation) by personnel who do not have direct responsibility for performing the activities being audited. The results of such audits are generally required to be documented, reported to, and reviewed by, responsible management. Follow-up action will be taken where indicated. The responsible organization can then take follow-up action as needed.

An effective auditing program is a useful tool for improving environmental compliance. If developed properly, the program will point out areas of weakness and areas of potential problems. An auditing program will also identify environmental compliance activities that meet or exceed expectations.