Why Audit?

Businesses and industries have been significantly affected by the rapidly changing, complex, and increasingly stringent environmental regulations promulgated by federal, state, and local governmental agencies.

To address these issues, regulated businesses and industries can successfully use environmental auditing strategies (environmental compliance audits and environmental management audits) to monitor their environmental programs and compliance status, evaluate their environmental management programs, and control potential regulatory compliance violations, environmental risks, and financial liabilities.

Leed Environmental, Inc. Services

Leed Environmental, Inc. has provided environmental auditing services for more than 250 facilities. The scope of work performed by Leed Environmental, Inc. has frequently included:

• Developing environmental monitoring and compliance programs
• Performing comprehensive environmental compliance and management audits
• Reviewing proposed and final environmental regulations (federal, state, and local) related to:
• Air quality
• Water and wastewater
• Solid waste (for facilities regulated under Subtitle D of RCRA)
• Hazardous waste (generators; transporters; treatment, storage, and disposal facilities; used oil and universal wastes, and oil and petroleum)
• Underground and aboveground storage tanks
• Superfund
• Emergency planning and community right-to-know
• PCBs, asbestos, and lead-based paint (for facilities regulated under the Toxic Substances Control Act)
• OSHA health and safety regulations
• Preparing technical comments and position papers on proposed regulations for submission to regulatory authorities
• Developing environmental compliance programs (written procedures, compliance manuals, etc.) and conducting training courses to instruct facility personnel on compliance activities
• Preparing and revising/updating environmental permit applications, negotiating the terms of environmental permits with regulatory agencies, and implementing compliance requirements
• Developing, implementing, and managing an environmental health and safety auditing program and an environmental performance assessment system
• Developing and implementing corrective measures to address any areas of noncompliance
• Conducting follow-up activities to ensure that corrective measures were implemented and maintained
• Conducting environmental studies, analyzing environmental trends, and resolving issues

Environmental Audit Goals

The U.S. Environmental Protection Agency defines an "environmental audit" as a "systematic, documented, periodic and objective review by regulated entities of facility operations and practices related to meeting environmental requirements" (65 Fed. Reg. 70, 19625 (2000)). Although environmental audits may be performed in many ways for different purposes, the reasons for performing an audit and the goals to be achieved will determine the type of environmental audit to be performed. The goals of an environmental audit typically include:

• Verifying compliance with environmental regulations
• Assessing the effectiveness of environmental management systems
• Evaluating short-term and long-term physical and financial risks and liabilities from the management of regulated and unregulated materials
• Determining the underlying causes of those risks and liabilities
• Providing data for sound decision-making to minimize risks and liabilities
• Gathering information to evaluate potential environmental contamination associated with property acquisitions
• Evaluating the performance and suitability of waste management companies and contractors
• Maintaining a proactive company position toward environmental issues, thereby enhancing a positive image to regulatory agencies, customers, and the public

The proper design of an environmental audit requires a careful evaluation of the goals and objectives of the program and development of a strategy to correct deficiencies identified during the audit.

Environmental Compliance Audits

An environmental compliance audit is performed to provide a "snapshot" of a facility's compliance status with applicable environmental laws and regulations at the time of the audit. Generally, the primary short-term objective of an environmental compliance audit is to evaluate the facility's compliance status and bring the facility into full compliance with existing regulations. An environmental compliance audit typically consists of three major tasks, which include:

• Task 1: Pre-Audit (Planning) Activities:
• Developing and Issuing Pre-Audit Questionnaire
• Reviewing Facility Background Information
• Preparing Audit Materials and Protocols
• Task 2: On-Site Audit (Examining and Evaluating Information):
• Opening Meeting
• Collecting Data:
• Facility Inspection
• Records Reviews
• Interviews
• Initial Data Analysis to Develop Findings
• Closing Meeting
  
• Task 3:  Post-Audit Activities (Communicating Results):
• Preparing and Issuing Final Report
• Developing Corrective Action Plan and Implementing Corrective Actions

Environmental compliance auditing is often used by regulated businesses and industries as a first-level strategy for evaluating and controlling environmental liabilities.

Environmental Management Audits

An environmental management audit is a distinct type of audit designed to evaluate the ability of a business or industry to implement its environmental management program. Specific types of environmental management audits, which may be used in conjunction with an environmental compliance audit, include:

• Management Audits, which are conducted to assess a facility's ability to carry out its environmental management program, and which normally involve a review of the company's organizational structure, staffing levels, personnel responsibilities, staff training and expertise, standard operating procedures, and available resources which help the facility to identify the cause of deficiencies and implement permanent corrective measures.

• Waste Disposal Facility/Vendor Audits, which are performed before issuing a waste disposal contract, to evaluate off-site, commercial treatment, storage, and disposal facilities to minimize the long-term risk and potential liabilities associated with off-site waste treatment and disposal activities.

• Pollution Prevention Opportunity Audits, which are used to evaluate options for minimizing or eliminating wastes and environmental releases, typically by best management practices, organizational/management changes, material substitutions, or process modifications.

• Environmental Site Assessments, often called environmental due diligence or liability audits, which are typically used in conjunction with real estate transactions to evaluate the potential presence of soil or groundwater contamination at a facility.

Collectively, environmental management audits involve the review of managerial risk control systems and procedures used by the businesses and industries to detect and correct potential deficiencies and violations. Because they focus on the underlying causes of the deficiencies and violations, environmental management audits are typically performed as a second-level auditing strategy and assist business and industries in implementing permanent corrective measures.