EHS Audits
Surveys of
Industry Practices
We have conducted surveys of current industry
practices in environmental auditing. One survey
was of the environmental auditing practices
of 19 major corporations within a variety of
industries and provides a perspective of the
current state of the art of environmental auditing,
as well as some important differences in organizational
approaches. In another survey, we reviewed the
corporate environmental audit reporting practices
of 13 companies. Here the reporting, data handling,
and follow-up processes of selected leading
environmental auditing programs were analyzed
in-depth to develop perspectives on the diversity
in audit reporting techniques, formats, and
approaches to provide clear and appropriate
disclosure of audit findings. In addition, we
have informally surveyed hundreds of companies
at our various audit seminars and workshops.
External Environmental
Auditing for the Board of Directors
Working for a committee of the boards of directors
of several major U.S. companies, we serve as
external auditors and conduct an independent
environmental verification program. As part
of these client assignments, we assist the corporation
to further develop and strengthen its internal
EHS, and product safety audit program. The boards
of directors find our assistance to be very
valuable to them in assuring compliance.
Independent
Compliance Audits
We have been asked by several leading chemical
manufacturers to independently conduct comprehensive
audits of the EHS compliance status of the corporations'
major plants with respect to federal, state,
and local laws and regulations and corporate
policy. Our audit reports typically include
findings about the compliance status of the
plant, as well as observations on the strengths
and weaknesses of the overall management approach
and the plant's environmental management and
control systems. Frequently these audits have
led to a decision to develop an internal audit
program, and we are asked to assist in its development.
Audits in
Highly Sensitive Situations
Working for outside counsel in dozens of highly
sensitive situations, we conduct audits of numerous
facilities that pose significant environmental
problems. In one such assignment, a team of
audit experts conducted several field visits
to independently determine compliance with federal,
state, and local environmental regulations;
assess whether facility operations and practices
pose potentially serious health or safety risks;
and determine conformance with corporate policies
and procedures.
Independent
Environmental Audits as a Result of a Criminal
Enforcement Action
When a plant in a major U.S. paper products
manufacturer became the focus of a criminal
enforcement action by the U.S. Environmental
Protection Agency (EPA), the parent company
asked us to conduct independent environmental
audits of the division's facilities on a rush
basis. Within two weeks of the request, we fielded
audit teams of up to six auditors for each of
the seven facilities and completed the audits
over a five-week period. The purpose of the
audits was to identify those areas where the
facilities were not in compliance with federal,
state, and local environmental regulations,
company policies, and good industry practices,
and to assess the status of each facility's
environmental management systems.
Comprehensive
Audits
For a large New Jersey corporation, we conducted
a comprehensive audit of compliance with federal
and state clean water regulations at 13 facilities.
Since large quantities of petroleum products
are received, stored, and consumed at these
facilities, our assessment includes a review
of both the physical and management systems
in place to meet regulatory requirements and
prevent releases of oil to state waters. Included
are marine transfer operations from barges to
shoreside facilities, containment systems around
transfer and storage equipment, and emergency
plans and equipment for responding to spills
and other emergencies. At the conclusion of
each facility visit, we evaluate compliance
with U.S. Coast Guard, EPA, and New Jersey Department
of Environmental Protection regulations, as
well as conformance with good industry practice,
and we make recommendations that will help the
facility achieve full compliance with the applicable
requirements.
Independent
Assessment of the Trans Alaska Pipeline System
and the Alyeska Pipeline Service Company
We were the contractor on this 10-month program
to perform an independent assessment of the
Trans Alaska Pipeline System (TAPS) and the
Alyeska Pipeline Service Company. The purpose
of the assessment was to identify any issue
that could compromise the operational integrity
of TAPS, and to provide baseline information
for implementing the Alyeska Integrity Management
System (AIMS). The assessment was under our
direction, carried out on an accelerated schedule,
and completed in two phases. The assessment
teams were composed of our experienced technical
experts, as well as personnel from five of the
TAPS Owner Companies. A total of almost 80 technical
personnel participated in the assessment teams,
which were led by our team leaders. Prior to
the initial fieldwork, the assessment team members
received training in our auditing methodology
and protocols. The assessment covered compliance
with federal, state, and local EHS regulations,
grants, permits, Alyeska policies and procedures,
and industry standards and operational integrity
issues along the 800-mile pipeline from the
Alaskan North Slope to the Port of Valdez, Alaska.
Reports were generated based on information
gathered by the assessment teams during their
fieldwork. Presentations of the interim and
final reports were made to the TAPS Owner Companies,
Alyeska management, and appropriate regulatory
agencies.
Evaluation
of Facility-Level Environmental Compliance and
Management Systems
For a large international manufacturer of industrial/agricultural
equipment, we developed a program to evaluate
the environmental compliance and management
systems in place at the facility level. The
purpose of the assessments was to identify those
areas where environmental risks had not been
identified or had not been adequately addressed
and to evaluate the management systems in place
to direct environmental issues. We provided
two to six team members with project- and industry-specific
expertise for each assessment. The assessments
involved interviews with management, engineering,
maintenance, and operational personnel; inspections
of environmental activities; and review of environmental
documentation and programs. Following the completion
of each assessment, a report was prepared which
included an evaluation of individual management
system elements (e.g., training, risk assessment/
management, roles and responsibilities) and
a list of compliance issues. To date, approximately
20 assessments have been completed.
Environmental
Audit and Management Assistance for Oil and
Gas Operations on Alaska's North Slope
For a major U.S. oil and gas corporation, we
were asked to assist corporate management in
the implementation of an EHS audit program designed
by us and recommend ways of further enhancing
EHS management within the corporation. The environmental
focus of this extensive Arctic audit program
of oil field facilities was on both facility-specific
and field-wide ecological and impact mitigation
issues, such as tundra restoration. Elements
of the compliance audit of both fixed facilities
and field-wide infrastructure included surface
drainage alterations, water quality, facility
effluent discharges, and tundra/wetlands protection
issues under the federal Clean Water Act. We
also evaluated facility compliance with state
and local regulations and permit requirements
governing the monitoring of operational impacts
to aquatic and terrestrial biota and ecosystems,
and assessed the adequacy and effectiveness
of existing management systems for tracking
and resolving ecological impact/mitigation issues
and systematically implementing permit-mandated
monitoring programs.
Development
of Internal Environmental Auditing Programs
We have assisted the management of over 200
corporations in the development of an internal
environmental auditing capability. Typically
this work has included assistance in designing,
testing, and implementing the audit program.
While the basic objective of these programs
is typically to verify compliance with corporate
and regulatory standards at the operating facility
level, additional specific program goals are
identified that take into account the corporation's
overall environmental management approach.
Critique
of Divisional Audit Programs
For a Fortune 100 corporation, we were asked
to assess the effectiveness of five environmental
auditing programs established by various divisions
of the corporation. We critiqued each of the
division's programs in the context of corporate
requirements; identified the strengths, limitations,
and potential pitfalls of each program; and
recommended ways to enhance the overall effectiveness
of the programs.
Evaluation
of an Internal Audit Program
We independently evaluated the design of a small,
privately-held company's internal environmental
audit program. In addition to assessing the
strengths and weaknesses of the environmental
audit program, we provided counsel to management
on environmental auditing practices, procedures,
standards, and trends.
Developing
International Audit Protocols and Questionnaires
We assisted several clients by developing audit
protocols and questionnaires specifically tailored
to their international operations. These protocols
and questionnaires enabled the auditors to identify
more effectively significant concerns despite
limited familiarity with local laws and regulations.
In one recent assignment for a multinational
corporation based in the United States, we were
asked to develop environmental audit protocols
for use by the company's corporate staff in
conducting audits of facilities in several countries.
Drawing on our library of international regulations,
we developed audit protocols for Brazil, the
United Kingdom, France, Germany, Italy, Mexico,
and Singapore. Each of the protocols included
specific references to the federal regulations
of the individual countries and, where appropriate,
included the regulatory citations.
Environmental
Auditing Workbook
For Edison Electric Institute, we wrote the
Environmental Auditing Workbook, a handbook
to provide electric utilities with in-depth
information needed to develop environmental
auditing programs and conduct environmental
audits. We also wrote a companion book, Environmental
Auditing Skills and Techniques Workbook,
to provide the field auditor with the basic
skills and techniques needed to conduct an effective
audit.
Canadian
Environmental Auditing Roundtable
In 1986, we sponsored the first Environmental
Auditing Roundtable for Canadian industry. The
meeting provided a unique forum for participants
to jointly discuss areas of common interest
with respect to their own internal environmental
auditing programs. Since then, we have sponsored
annual Canadian Environmental Auditing Roundtable
meetings.
Environmental
Management Systems Assessment of a Major U.S.
Computer Manufacturer
A major U.S. computer manufacturer was preparing
to initiate a company-wide environmental audit
program and desired a more effective management
systems structure within which to administer
the new audit program. We assessed the corporate
environmental and industrial hygiene management
systems and evaluated the current implementation
of eight specific corporate EHS programs. We
provided the client with numerous recommendations
to enhance the effectiveness of its corporate
and operating groups' EHS and line managers
within the company's overall environmental and
industrial hygiene management systems.
