An environmental compliance audit is an independent evaluation of a company’s environmental legal requirements and an assessment of how the company complies with those requirements. This tool allows companies to evaluate and quantify their environmental performance and to pinpoint problems with compliance or management system implementation. The purpose of an environmental compliance audit is to ensure that the company is following all the applicable regulations and laws, as well as internal guidelines, controls, policies, and procedures.1 Failure to comply with environmental regulations may result in undesirable consequences such as financial penalties and even criminal prosecution. Regularly conducting both internal and external compliance audits is essential for organizations to avoid these outcomes. Environmental compliance audits ensure both environmentally sustainable business operations and transparency for stakeholders with an interest in the company’s environmental impact.
Types of Environmental Audits
There are two main types of environmental audits:
- Environmental Compliance Audit (External)
This is the most comprehensive type of environmental audit, as it entails a review of the construction site or company’s legal compliance status. It is also the most common of the two types of audits.
2. Environmental Management Audit (Internal)
Internal audits are conducted by the organization or management in order to understand how it is meeting its own environmental performance expectations.
What is the Environmental Compliance Audit Process?
An Environmental Compliance Audit is conducted by an external and independent auditor. This means they have no business, financial, or personal interest in the outcome of the audit. The auditor will assemble all pertinent data prior to and during a site visit (if applicable). They would then analyze the facts, compare them with the criteria for the audit, draw conclusions, and report their findings.2
An External Environmental Compliance Audit can be simplified into three steps:
The auditor will determine which environmental laws, policies, and procedures are applicable to the operations of the business, as well as determine the scope and objectives of the audit. The auditor must establish the criteria against which the audit will be conducted. Common criteria are company policies and procedures on environmental issues, applicable legislation and regulations, and best environmental management practices.
2. On-site Audit
The auditor will conduct an assessment to determine whether the business is complying with the applicable environmental regulations, policies, and procedures.
The auditor must develop an understanding of the controls that are in place, including formal procedures and practices, record-keeping and monitoring, inspection programs, and physical controls for containing pollution and spills. Through testing, observation, or inquiry, the auditor will attempt to verify whether the controls work as intended. All information gathered is recorded and evaluated. Potential problems noticed on-site are discussed with the management team or contractors.
Following the on-site work, the next step is to prepare a report. The auditor will compile an Environmental Compliance Audit report which designates the status of the business as full compliance, partial compliance, or non-compliance. The report indicates the laws and policies the company follows and where the company is non-compliant. In the event of non-compliance, the report will provide advisory action to improve overall environmental legal compliance. The company has the option to request recommendations in the form of an action plan or not.
Once an audit program is in place, future environmental compliance audits will refer to past reports to look for repeat non-compliance, as well as to measure what progress has been made in the implementation of prior recommendations.
Benefits of Environmental Compliance Audits
An Environmental Compliance Audit can benefit companies in several ways:
- Ensures safeguarding of the environment
- Verifies compliance with local and national laws
- Indicates critical current or future problems and environmental impacts
- Assesses training programs, providing data for future environmental training
- Enables companies to build good environmental performance and highlight shortcomings
- Identifies areas for saving, such as waste minimization
- Demonstrates the company’s environmental protection commitment to employees, the public, other stakeholders, and the authorities
The United States Environmental Protection Agency (EPA) has published several audit protocols to assist the regulated community in developing programs to evaluate compliance to environmental requirements under federal law.3 These protocols, however, are only a guide. Companies’ legal obligations are determined by applicable environmental facility-specific permits, as well as federal, state, and local laws.
Environmental Compliance Audits can identify areas where the company is not compliant with obligations before environmental damage occurs. Companies then avoid liability and fines and actively participate in promoting a safer environment for everyone. However, audits will be a waste of time and money if the audit findings are not taken seriously, and the recommendations followed.
The SafetyStratus Research Advisory Group (RAG) brings together thought leaders from the global environmental, health, and safety community to promote best practices and provide key insights in the profession and the industries they serve. The Research Advisory Group also advocates, where practical, the intersection of and advances with the use of technology, such as the SafetyStratus enterprise EHS software platform. Group membership consists of representatives from across varied disciplines and market sectors as well as select members of the SafetyStratus team.
The primary objectives of the SafetyStratus RAG partnership are to:
- Build a strategic partnership between EHS practitioners and the SafetyStratus team.
- Provide engaging and practical content to the global EHS community.
- Provide discipline and market feedback specific to SafetyStratus products and services.
While the objectives of the RAG are varied, the primary public-facing outcome will be available through engaging and practical content found on the SafetyStratus resource pages. Various articles, papers, and other valuable resources will be produced and shared as part of an ongoing effort to cultivate a robust community. Ultimately, the SafetyStratus RAG will expand to have a broader reach and provide opportunities for more inclusion by all interested EHS professionals in a collaborative community environment.
1 Go Legal (2020) Environmental Legal Compliance Auditing – What is it and do I need to do it?. Website: https://www.golegal.co.za/environmental-legal-compliance-audit/ Accessed 03/09/2021
2 Encyclopaedia of Occupational Health and Safety (2011) Environmental Auditing – Definition and Methodology. Website: https://www.iloencyclopaedia.org/component/k2/item/748-environmental-auditing-definition-and-methodology Accessed 03/09/2021
3 USEPA. Audit Protocols. Website: https://www.epa.gov/compliance/audit-protocols Accessed: 03/09/2021