Pro-Tips for Best EHS Audits (Part 1): Planning An EHS Compliance Audit

Introduction

Environmental Health and Safety (EHS) audits help organizations confirm that EHS risk is being managed to an acceptable level.  Processes for conducting EHS audits continue to evolve.  This three-part article will explore why and how EHS audits are performed.  The techniques are based on principles of auditing that have been used for many decades by financial accountants.  These techniques are now being adapted to audits of EHS performance.  EHS audits assess EHS regulatory compliance, management systems conformance and other important areas of EHS performance. This part of the three-part series explores best practices for planning effective EHS audits.

Part 1 – Planning an EHS Audit

Planning an EHS audit starts with understanding the purpose and objective of the audit.  Auditors need to understand who is requesting the audit (the audit client) and what the audit results will be used for.  This information helps auditors define the scope of the audit and what resources will be needed to achieve the audit objective.  Documenting and sharing the audit objective and scope early in the audit planning process helps ensure there is agreement between the auditor and the auditee.  Figure 1 is an example of how an auditor might document the audit Objective and Scope as part of developing and EHS audit plan.

Audit Objective and Scope statement in an audit plan

Figure 1 – Audit Objective and Scope statement in an audit plan

Determining EHS Audit Duration

With the objective and scope confirmed, an auditor can determine how much time will be required to perform the audit (audit duration). This includes estimating time to plan the audit, collect audit evidence, review the evidence and prepare a report of the audit findings and conclusions.  Sometimes the auditor needs to conduct a preliminary Stage 1 audit to help judge auditee readiness, gather additional information to determine the audit duration and confirm the audit is feasible. Differences between the duration proposed by the auditor and what the audit client is willing to pay, need to be resolved before the audit begins. Changing the scope of the audit can often help the auditor and auditee reach consensus on the duration of the audit.

Auditor Competence

The confidence that can be placed in the results of the audit are directly proportional to the auditors competence. Auditor competence includes knowledge of the regulatory requirements (the audit criteria) and the processes that are the subject of the audit. Audit team members should also have developed audit skills including, how to conduct interviews, how to follow audit trails and how to record audit evidence.  Auditor behaviors are also critical including maintaining confidentially and making the auditee feel at easy during the audit.

Preparing an EHS Audit Schedule

With the audit duration established competent auditors can now develop and document a plan to conduct the active evidence gathering part of the audit.  The plan should identify where the auditor plans to audit, when they plan to be there and what evidence they will be evaluating.  It can also include who the auditors intend to interview during the audit.  This helps the auditee schedule meetings with the auditor and avoid delays in the audit due to interviewee being unavailable when the auditor desires to conduct the interview.   

Confirming the Audit Schedule

Once the audit plan is established it should be shared with the audit client and the auditee to ensure agreement on when, where, and how the audit will be conducted.  When agreement is reached the auditor can begin to make plans for travel and accommodations during the onsite portion of the audit.  Figure 2 is an example audit schedule for a hypothetical metal parts manufacturing facility that also has an electroplating process.

Example EHS Compliance Audit Plan

Figure 2 – Example EHS Compliance Audit Plan

Summary

In this part of the 3-part compliance audit series we explored how to plan an EHS audit.  In Part 2 of the series, we will explore how to conduct an EHS audit by following audit trails and recording audit evidence.  In part 3 we will explore processes for reporting and following up on the results of an EHS audit.

ECSI provides auditing, consulting and training services to organizations interested in improving their EH&S performance. For more information, contact us.

This is the first of a three-part article that describes best practices for planning, conducting, and following up on environmental and occupational health and safety regulatory compliance audits.

This three-part series we will consider best practices for:

  • Part 1 – Planning audits
  • Part 2 – Conducting audits
  • Part 3 – Following up on audit results
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About Kevin Lehner

Kevin has been president of ECSI for over 25 years. His practice focuses on environmental and health and safety management systems training, consulting and auditing. He is an active member of the US Technical Advisory Committees to ISO 14001 and ISO 45001. He represents that USA at international meetings of these committees. He is also the lead developer of the CorrectTrack corrective action tracking app.