Have you ever heard the phrase “ignorance is bliss”? I’m sure we all have. Unfortunately, that phrase isn’t always correct, especially when it comes to environmental and safety regulatory infractions. Setting aside the moral obligation to protect our workforce and natural resources, with documented fines reaching the million dollar mark many businesses simply can’t afford to not comply. So, how can YOU protect YOUR business? The best way to prevent regulatory non-compliance is to conduct an environmental, health and safety (EHS) audit. In the following paragraphs we will cover how to prepare for an EHS audit, what things to look for during the site inspection portion of the audit and how to go about reviewing your data and records.
Preparing for an EHS audit can be a daunting task if you don’t know where to begin. A good place to start is by pulling together any regulatory permits, plans, records and reports that have been prepared for the facility over the course of the past several years. You will want to review the recordkeeping requirements for each regulation to determine how many years of records you should be reviewing. For example, in most states facilities are required to maintain hazardous waste manifests for a period of three years. If this is the case in your state, you will want to ensure you review the past three years of hazardous waste manifests during the audit.
Now that you have all of your paperwork ready for review, you will want to head out on an inspection of the facility. During the inspection, take note of floor practice to ensure they are in line with the regulatory requirements. For example, is universal waste stored in containers that are correctly labeled? Are electrical panels blocked? During the site inspection you will also want to ensure all equipment located at the facility is documented accurately in any and all permits/plans. Keep an eye out for equipment operating onsite that should be included in the facility’s permits/plans but is not. This is something regulators will be checking if and when they visit your facility. Be sure to ask questions and look everywhere; you never know where the skeletons are hidden until you search for them!
Now that you have completed the site inspection, the fun begins! Review all permits and plans to determine if all of the permit conditions are being met. For example, if your air permit requires daily pressure drop readings on a control device, do you have the records that document the daily checks? Are you doing what you said you were going to do? If your Spill, Prevention, Control and Countermeasure (SPCC) Plan says you will conduct monthly inspections, are you? Are annual safety trainings being conducted and does the training contain the required content? Are reports being submitted timely and accurately? Are you aware of ALL of the EHS regulations that are applicable to your facility? If not, seek the assistance of an EHS consultant. After all, we have learned that ignorance is not bliss!
Once you have completed the site inspection and reviewed all of your permit, plans and records, you will want to create an audit report. The audit report should document all of the regulations reviewed, the compliance status of your facility related to each regulation and the necessary steps that need to be taken to resolve any regulatory deficiencies. At the end of the auditing process, you should have some peace of mind knowing that while there are areas for improvement at your facility, you have a roadmap to compliance.