Authors: Lawrence B. Cahill
ISBN-13: 9780865878259, ISBN-10: 0865878250
Format: Hardcover
Publisher: Government Institutes
Date Published: January 2001
Edition: 8th Edition
This expanded edition of Environmental Health and Safety Audits brings you up-to-date on changes in EPA and OSHA auditing policies, issues currently confronting auditing programs, and state-of-the-art strategies for managing and conducting audits. The author discusses new developments in information generation and availability, including new chapters on meeting ISO 14000 auditing guidelines, auditing dilemmas, and auditing tips, and new tools for building a successful audit program, including seven model program stages.
List of Figures and Exhibits | xx | |
Preface | xxiii | |
About the Editor and Principal Author | xxv | |
Contributing Authors | xxvii | |
Acknowledgments | xxxi | |
Part I | Managing a Program | |
Chapter 1 | Perspectives in EH&S Auditing | 3 |
Why Audit? | 3 | |
Impact on the Regulated Community | 11 | |
Evolution of Environmental Auditing | 16 | |
EH&S Auditing Organizations | 17 | |
Defining Environmental Audits | 18 | |
Advantages and Disadvantages | 20 | |
Trends in EH&S Auditing | 21 | |
Chapter 2 | Government Perspective | 25 |
Introduction | 25 | |
U.S. EPA Policy Encourages Use of Environmental Auditing | 27 | |
U.S. EPA's 1986 Auditing Policy and Elements of Effective Audit Programs | 28 | |
U.S. EPA's Audit Policy | 30 | |
Conclusions | 44 | |
OSHA's 2000 Self-Audit Policy | 44 | |
Chapter 3 | Legal Considerations | 47 |
Introduction | 47 | |
Function of Environmental Assessments | 48 | |
Role of Environmental Assessments | 49 | |
Federal Policies Encouraging Environmental Assessments | 50 | |
Protection Of The Confidentiality Of Environmental Assessments Under Existing Law | 55 | |
State Environmental Audit Legislation and Policy | 60 | |
Practical Considerations and Recommendations For Performing Self-assessments | 61 | |
Chapter 4 | Elements of a Successful Program | 65 |
Principles of an Audit Program | 65 | |
Planning the Program | 66 | |
A Key Program Issue: Corporate Standards and Guidelines | 84 | |
Additional Sampling | 87 | |
Continuous Review | 87 | |
Evaluating the Results and Implementing the Solutions | 88 | |
Chapter 5 | Impact of International Standards on EH&S Audit Programs | 89 |
The Key Initiatives | 91 | |
Corporate Responses | 102 | |
Conclusion | 108 | |
Chapter 6 | The Challenges of Meeting ISO 14000 Auditing Guidelines: Audit Program Gaps | 109 |
A Process to Evaluate the Adequacy of Resources | 110 | |
A Process to Evaluate Auditee Cooperation | 111 | |
A List of Auditees in the Audit Report | 112 | |
Identification of "Obstacles Encountered" in the Audit Report | 113 | |
Documentation of "Findings of Conformity" | 115 | |
An Appropriate Code of Ethics | 115 | |
A Non-Disclosure or Records Retention Policy | 116 | |
A Formal Audit Plan | 117 | |
Auditor Independence | 118 | |
Sufficient Program Guidance Documentation | 118 | |
Chapter 7 | A Review of Some Typical Programs | 119 |
Program Overview and Scope | 120 | |
Program Methodology | 123 | |
Program Operations | 126 | |
Conclusion | 127 | |
Chapter 8 | Benchmarking EH&S Audit Programs: Best Practices and Biggest Challenges | 129 |
Overview of Benchmarking | 130 | |
Best Practices | 133 | |
Biggest Challenges | 139 | |
Chapter 9 | Environmental Auditor Qualifications: Great Expectations | 143 |
Core Skills | 144 | |
Observations in the Field | 146 | |
Making Good Things Happen | 148 | |
Conclusion | 148 | |
Chapter 10 | Training EH&S Auditors | 149 |
The Need | 149 | |
Selecting the Trainers | 150 | |
Selecting the Trainees | 151 | |
Selecting the Setting | 151 | |
Selecting the Techniques | 152 | |
Chapter 11 | EH&S Audit Training in the Asia Pacific | 155 |
First Stop: Singapore | 156 | |
The Transition: Singapore to Japan | 159 | |
Second Stop: Japan | 159 | |
Chapter 12 | Information Management | 163 |
Regulatory Databases | 164 | |
Automated Checklists | 165 | |
Evaluating Auditing Software Systems | 168 | |
Chapter 13 | Using Groupware to Manage the EH&S Audit Program Documentation Process | 171 |
Importance of Sound Information Management | 171 | |
Traditional Responses to Audit Document Management | 172 | |
The Groupware Solution | 174 | |
Conclusion | 177 | |
Chapter 14 | Managing and Critiquing an Audit Program | 179 |
Beginning a Program | 179 | |
Managing a Program | 184 | |
Conclusion | 189 | |
Part II | Conducting the Audit | |
Chapter 15 | Conducting the EH&S Audit | 193 |
Introduction | 193 | |
Pre-audit Activities | 194 | |
On-Site Activities | 205 | |
Chapter 16 | Typical Compliance Problems Found During Audits | 223 |
EH&S Audits: What Can Go Wrong? | 223 | |
Common Compliance Problems | 224 | |
Typical Inspection Areas | 231 | |
Auditor's Reminder Checklist | 262 | |
Chapter 17 | Conducting Effective Opening and Closing Conferences | 267 |
Opening Conferences | 268 | |
Closing Conferences | 272 | |
Chapter 18 | Auditing Dilemmas | 279 |
The Management Systems Defense | 279 | |
The De Minimis Issue | 280 | |
Virtual Compliance | 281 | |
Unobtainable Verification | 281 | |
Non-Specific Corporate Standards | 281 | |
Conflicts Between Country Regulations and Corporate Standards | 282 | |
Repeat Findings | 283 | |
Just-in-Time Compliance | 283 | |
Regulatory Intent | 284 | |
Vague Regulatory Definitions | 284 | |
Chapter 19 | Preparing Quality EH&S Audit Reports | 287 |
Field Preparation | 288 | |
Report Preparation | 290 | |
Report Follow-Up | 301 | |
Chapter 20 | Environmental Auditing: A Modern Fable | 305 |
The Company | 305 | |
The Audit | 306 | |
The Beginning | 307 | |
The First Meeting | 307 | |
The Field Work | 308 | |
That Night | 309 | |
The Next Day | 310 | |
Finishing | 311 | |
The Briefing | 311 | |
The Report | 313 | |
Epilogue | 317 | |
Chapter 21 | Achieving Quality Environmental Audits: Twenty Tips For Success | 319 |
Do Not Ignore or Underestimate the Need to Prepare for and Plan the Audit and Its Logistics | 319 | |
Develop and Maintain a "Living" Agenda throughout the Audit | 320 | |
You Will Never Finish So Manage Your Time Wisely | 320 | |
Keep a Balance between Records Review, Interviews, and Observation | 321 | |
"Things" Will Happen on the Audit. Be Flexible | 322 | |
Always Be On Time Even When the Site Staff Are Not | 322 | |
Remember Site Staff Will Always Consider Audits a Performance Evaluation | 323 | |
In Spite of the Existence of Governmental Regulations and Company Standards, Considerable Judgment Is Still Required | 323 | |
Every Country, State, or Region Is Different | 323 | |
Learn and Apply the Audit Protocols, but Don't Forget to Use Your Common Sense and Natural Curiosity | 324 | |
Try to Observe Things as They Happen | 324 | |
Observe Ancillary Operations | 325 | |
Observe, Articulate, and Write, in That Order | 326 | |
True and Complete Root-Cause Analysis Can Be Complex, Difficult, and Time Consuming | 326 | |
Writing Is the Hardest Part; Developing "Bullet-Proof" Findings Is an Elusive Goal | 327 | |
Write the Findings as You Go | 327 | |
Prepare Well for the Opening and Closing Conferences | 328 | |
Make Sure the Site Hears the Real Story in the Closing Conference | 328 | |
Plan to Be Done When You Depart | 328 | |
Enjoy Yourself!!! | 328 | |
Part III | Special Auditing Topics | |
Chapter 22 | Property Transfer Assessments | 331 |
Introduction | 331 | |
Approach Overview | 334 | |
Scope and the ASTM Standard | 334 | |
Assessment Team | 334 | |
External Contacts | 335 | |
The Three Phases | 336 | |
Phase I337 | ||
Phase II344 | ||
Phase III344 | ||
Assessment Issues | 345 | |
Conclusion | 353 | |
Chapter 23 | Top Ten Reasons Why Phase I Environmental Assessment Reports Miss the Mark | 355 |
Failure To Maintain Independence and Objectivity | 357 | |
Failure To Define The Exact Scope of Work | 358 | |
Use of Conjecture in Report Findings | 359 | |
Use of Imprecise Language | 359 | |
Failure to Distinguish "Compliance" Findings From "Liability" Findings | 360 | |
Documented Sources | 361 | |
Failure to State Assumptions Regarding Cost Estimates in Assessment Reports | 362 | |
Lack of Editing and a Quality Assurance Review | 363 | |
Disputes Over Disclaimers | 364 | |
Failure to Write the Report as a Business-Decision Tool | 365 | |
Chapter 24 | Waste Contractor Audits | 367 |
Objective and Scope of a TSD Facility Audit Program | 369 | |
Internal Programs vs. External Programs | 370 | |
Conducting the TSD Facility Audit | 372 | |
Pre-Audit Preparation | 372 | |
Special Pre-Audit Considerations | 375 | |
Selecting the Audit Team | 378 | |
The On-Site Audit | 379 | |
The TSD Facility Audit Report | 383 | |
Conclusion | 385 | |
Chapter 25 | Waste Minimization or Pollution Prevention Audits | 387 |
Why a Pollution Prevention Focus? | 387 | |
The General Approaches | 388 | |
Limitations and Constraints | 389 | |
Methodology | 389 | |
Examples of the Presence of a Waste Minimization Effort | 393 | |
Chapter 26 | Evaluating Management Systems on EH&S Audits | 395 |
Why Evaluate Management Systems? | 395 | |
What is a Management System? | 396 | |
How Do You Do It? | 398 | |
Practical Tips | 400 | |
Why is It So Hard? | 401 | |
Conclusion | 402 | |
Chapter 27 | International EH&S Audits | 403 |
Role of Corporate Management | 405 | |
Design of International Audit Programs | 406 | |
Conducting International Audits | 410 | |
Summary of Key Challenges in International Audits | 413 | |
Appendices | ||
Appendix A | References | 419 |
Appendix B | Federal Register Notes | 423 |
Appendix C | Sample EPCRA Audit Protocol | 455 |
Appendix D | Problem Solving Exercises | 477 |
Appendix E | Summary of Audit Programs | 555 |
Appendix F | Model EH&S Audit Program Manual | 581 |
Appendix G | Model Pre-Audit Questionnaires for EH&S Audits | 615 |
Appendix H | Model EH&S Audit Opening Conference Presentation | 645 |
Appendix I | Model Environmental Audit Report | 653 |
Appendix J | Model Environmental Audit Appraisal Questionnaire | 671 |
Appendix K | Model Management Presentation | 675 |
Appendix L | Sample Site Assessment Report | 683 |