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Module 3

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© © All Rights Reserved
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 An audit is a systematic, independent and

documented process for obtaining audit evidence


and evaluating it objectively to determine the
extent to which audit criteria are fulfilled
 An internal quality audit is an audit that is
performed by or at the direction of members of the
organization
Possible reasons to audit
 ensure compliance with ISO 14001
 ensure compliance with organization requirements
 ensure compliance with regulatory requirements
 ensure the QMS is effectively implemented and
maintained
Auditing for improved performance
 look for opportunities for improvement
 look for best practices that could be applied in
other areas
 look for preventive action
 look for outstanding emphasis on customer
satisfaction
 Ethical conduct
 Fair presentation
 Professional care
 Independence
 Objectivity
 Impartiality
 Evaluations based on evidence
 Competence
 Cooperation
 Trust
 External independent audits – third party
 Customer audits of suppliers – second party
 Internal audits – first party
External independent audits – third party

 Conformity to a specific standard


Customer audits of suppliers – second party

 Conformance to customer requirements

 Customer’s special interest items


Internal audits – first party

 Performance to the organization’s objectives

 Identification of problem areas

 Finding opportunities for improvement


 Evolving nature of quality management
 Internal focus vs. customer focus
 Control vs. improvement
 Quality Audit by QA vs. QA by organization
 Leadership: from QA or from management
 Documented procedures vs. manage processes
 Alignment of business, policy and objectives
Principle 4 – Process Approach
 A desired result is achieved more efficiently when
activities and related resources are managed as a
process.

Principle 5 – System approach to management

 Identifying, understanding, and managing interrelated


processes as a system contributes to the
organization's effectiveness and efficiency in achieving
its objectives
a) Audit preparation
 Audit preparation consists of everything that is
done in advance by interested parties, such as the
auditor, the lead auditor, the client, and the audit
program manager, to ensure that the audit
complies with the client’s objective
 The preparation stage of an audit begins with the
decision to conduct the audit
 Preparation ends when the audit itself begins.
b) Audit performance
 The performance phase of an audit is often called
the fieldwork
 It is the data-gathering portion of the audit and
covers the time period from arrival at the audit
location up to the exit meeting
 It consists of activities including on-site audit
management, meeting with the auditee,
understanding the process and system controls
and verifying that these controls work,
communicating among team members, and
communicating with the auditee
c) Audit reporting
 The purpose of the audit report is to communicate
the results of the investigation
 The report should provide correct and clear data
that will be effective as a management aid in
addressing important organizational issues
 The audit process may end when the report is
issued by the lead auditor or after follow-up
actions are completed
d) Audit follow-up and closure
 According to ISO 19011, clause 6.6, “The audit is
completed when all the planned audit activities
have been carried out, or otherwise agreed with
the audit client.”
 Clause 6.7 of ISO 19011 continues by stating that
verification of follow-up actions may be part of a
subsequent audit
 The lead auditor is responsible for the
organisation and management of the audit and
liaise with the client or the contact person in the
case of an internal audit
 The lead auditor is also responsible for the
organisation, recruitment and management of the
audit team and ensuring that the necessary
deliverables from the audit, including the audit
report, are delivered according to the agreed
timetable and plan.
 The auditor will undertake auditing tasks, alone or
as a member of a team, and must be conscious of
the ethical and professional responsibilities of his
task
 This will include ensuring that the audit work is
thorough, fair and accurate.
 In some cases, a technical expert will be included
as a part of an audit team to assist with
understanding and interpreting technical aspects
of the operation or site being audited
 The technical expert does not necessarily have to
be an auditor but it does help.
 Audit team must work together, under the
leadership of the lead auditor, to ensure
completion within the brief and scope of the audit
 Team must be mindful that their activities could
disrupt the normal operations of a site or plant and
therefore must minimise the negative impact of
their inquiries.
 The client is the individual or organisation that
commissions the audit
 In the case of an external audit, it may be the
Chief Executive Officer of a company or the
Environmental Manager.
 In the case of an internal audit, it could be the
departmental head or the Audit Manager
 The client and auditee can sometimes be the
same individual, depending upon the structure and
system within an organisation or company.
Education needed to become an ISO Auditor
 To become an ISO auditor, need at least a diploma,
certificate or associate’s degree from a technical
college in a field related to environmental
management, systems management or quality
assurance. Some employers may require bachelor’s
degree in one of the following fields

• Environmental Science
• Environmental Management
• Natural Resource Management
• Environmental Engineering
• Environmental Assessment
Who Hires ISO Auditors?
ISO auditors may be employed by or work on a contract
basis for such organizations as-
• Engineering, environmental and systems
management consulting firms
• Federal, provincial/state and municipal
government departments
• Utility companies
• Manufacturing firms
• Resource-based companies (agriculture, forestry,
mining, oil and gas)
• Self-employment (on a consultancy basis)
 These are audits which are specifically designed
to check and evaluate the effectiveness of
environmental management systems.
 Sound environmental management at a site or in
an operation depends upon procedures, work
instructions, guidelines, specification, training
programmes and monitoring systems being
implemented by the employees of the organisation
operating on the site.
 Environmental compliance (or performance) audits
are specifically designed to test compliance (which
covers both legal compliance and corporate
compliance) to environmental policies, objectives,
laws, by-laws, ordinances, regulations and
standards.
 Include more numerical testing and specific
checks on, for example, compliance with
requirements in water and air permits and
licenses.
 An environmental assessment audit is an
instrument used to check that an Environmental
Impact Assessment complies with the minimum
legal requirements and also checks to ensure that
due legal process has been followed.
 To assist in EIA quality control and to reduce
unnecessary costs and inconvenience
 Waste audits are environmental audits which
specifically look at the waste management
component of an operation or site

 In such audits, the various aspects of waste


management would be reviewed and the methods,
procedures and systems checked and verified.
 Environmental due diligence audits are essentially
audits which look at the actual and potential
environmental liabilities of a site or operation

 Most commonly carried out as a precursor to the


purchase of property which has been or is likely to
be used for industrial or commercial purposes
 Past dumping or burying of hazardous waste
which may result in pollutants contaminating the
groundwater

 Owner of the land where the waste was buried


could be held liable for the clean up costs

 When purchasing property, to ensure that the new


owner is not taking over someone else’s hidden
environmental liabilities
 A supplier audit is an audit carried out by a client
to test the environmental compliance of a
contractor or supplier

 It should be an audit using the environmental


conditions included in the contract document

 Not reflection on the quality of the contractor’s


service
 Contractor and client will have a contractual
relationship which is often based upon the supply
of a specific product or service

 Supplier or contractor audit is one where the


contractor is audited against the environmental
requirements of the contract
 Prepare detailed plans for each audit
 Execute each audit
 Report audit results including conclusions and
recommendations
 Corrective actions if needed
 Follow-up to ensure corrective actions are
effective
Scope of Audit
 The scope of the audit determines exactly what will be
done during the audit and what the deliverables of the
audit will be
 Typical scope or set of objectives would cover:
conformance with EMS criteria; whether or not the
EMS has been fully implemented and the system
maintained; areas of potential improvement for the
EMS; and effectiveness of internal management
review.
Planning of Audit
 The effective planning and logistics of an audit is
critical to ensure a successful audit
 Apart from ensuring that the appropriate staff are
available to answer audit questions, the logistics
of an audit needs to be organised to prevent
wasting time.
Pre-Audit Meeting
 A pre-audit meeting is an important prerequisite for the
audit because it is the first opportunity to meet the
auditee and deal with any concerns

 Gather any documentation that the audit team can


study before arriving on site

 Audit protocol and audit plan can be handed over at


this meeting and discussed in advance of the audit
itself

 Opportunity to reinforce the scope and objectives of


the audit and discuss practicalities associated with the
audit (e.g. access to key staff, photographs on site,
site tour, access to documentation, etc.).
Second pre-audit meeting (optional)
 Auditees may have concerns and questions
arising from the pre-audit meeting which cannot
be dealt with telephonically or by email

 Follow up meeting is entirely optional but may


assist in bolstering confidence in the audit process
and providing support for the auditee’s efforts to
establish internal auditing systems and processes
Auditor Meeting
 With more complex audits, it is useful to have an
auditor meeting before the audit to allocate
specific assignments to auditors and confirm
details and deadlines

 Logistics of this will vary enormously


Opening meeting

 First activity of the on-site audit and is the


opportunity to introduce the audit team to the site
staff
Site Tour
 Next part of the audit is the site tour which is
designed to familiarize the audit team with
activities and operations
Questioning, document review and evidence
gathering
 Core work of the audit is working through the audit
protocol, asking questions, checking answers
against site documentation (manuals, reports,
monitoring data, work instructions, procedures,
training schedules etc.), reviewing documentation
against standards, policies and action plans and
gathering evidence to support the answers to the
questions
Consolidation, audit findings and review
 Time must be allowed for the team to consolidate
its findings and prepare the basis for the
preliminary report back to be given at the exit
meeting
Exit meeting
 Run by the lead auditor and is the mechanism to
feedback broad, preliminary findings to site
management and staff before the audit team
leaves the site
Draft Audit report
 Information gathered by the audit team is
consolidated and written up as a draft audit report

 Draft report will then be circulated to the audit


team and those directly concerned with the audit

 Purpose is to check the report for accuracy.


Final Audit report
 Final audit report is the corrected final document
which contains the findings and recommendations
of the audit

 It will also form one of the base of future audits


because the information it contains informs some
of the tests and analyses that need to be
performed in the future.
Follow up and Action Plans
 Environmental audits form part of an on-going
process of continuous improvement
 Build upon information from previous audits and
create a baseline for future audits
 For this reason, follow up work in the form of
analyses of recommendations and action plans is
a crucial part of an audit
 In order to promote continuous improvement it is
recommended that the idea of the next audit be
discussed during the exit meeting
ISO 14001
NON-CONFORMANCE,
CORRECTIVE AND
PREVENTIVE ACTION
 A deficiency that seriously impairs the
effectiveness of the EMS

Examples
 An element of ISO 14001 not implemented
 Procedures not developed or not implemented
 Failure to take corrective or preventive action
 Several minor non-conformances
 A minor deficiency that does not seriously impair
the effectiveness of the EMS

Examples
 One or a few individuals (out of many) do not use
a procedure correctly
 Procedure needs minor changes to be effective
 One or a few records incomplete
 Corrective action fixes the immediate problem
(e.g., repair a leaking valve)
 Preventive action is designed to stop the problem
occurring again, or stop problems before it happen
(e.g., improved maintenance procedures)
 Effective preventive actions are a key to
CONTINUAL IMPROVEMENT
 The organization shall establish and maintain
procedures for defining responsibility and
authority for handling and investigating
nonconformance, taking action to mitigate any
impacts caused, and for initiating and
completing corrective and preventive action
 Any corrective and preventive action taken
to eliminate the causes of actual and
potential non-conformances shall be
appropriate to the magnitude of problems
and commensurate with the environmental
impact encountered
 Identify problem through routine inspection,
monitoring, audit findings, trend analysis,
employee comments, complaint, experience
 Investigate problem and its underlying causes
 Involve persons with first-hand knowledge of the
issues, and authority to achieve solutions
 Identify best solution(s) and persons responsible
for implementing them
 Ensure solution is adequate for the size
and nature of the problem, i.e., fix the
underlying cause(s) once and for all
 Follow-up with monitoring to confirm that
implemented solution is effective long-
term
 Involve people throughout with sufficient
influence to ‘make things happen’ promptly
PROBLEM
Environmental monitoring results not submitted to
government on time
Possible underlying causes
» Responsibility for reporting not clearly
communicated
» Inadequate training or awareness of reporting
schedule requirements
» Written procedure not available
» Insufficient supervision and checking
 Don’t ignore problems and hope they’ll go
away
Ask:
Who? What? When? How? Where?
WHY?
Until you arrive at the root cause of the
problem
 Fix deficiencies in the system, not just
symptoms of the problem
 The organization shall implement and
record any changes in the documented
procedures resulting from corrective and
preventive action
 This means that procedures must be kept
up to date (i.e., maintained) to include new
actions required to prevent previous
problems
MAJOR NON-CONFORMANCE
 Registration to ISO 14001 delayed until
problem is corrected and re-audited
MINOR NON-CONFORMANCE
 Can receive registration to ISO 14001 but
must commit to fix problem within 60 days;
correction will be confirmed on next audit
Important points to remember are
 Need open communication, without fear of
punishment for identifying a non-conformance
 Need somebody with authority incharge of
responding to non-conformances
 Need thorough investigation of symptoms and
underlying causes of each non-conformance
involving knowledgeable persons and those
affected by the non-conformance
Additional points to remember are-
 Need identification and implementation of
lasting solutions that change the system
(i.e., the way things are done), not just the
symptoms
 Need follow-up to ensure the solution
provides lasting improvement
 Need update documented procedures to
include corrective and preventive actions
Waste minimisation
• Government policy and regulations
• Technological feasibility
• Economic viability
• Management commitment and support
• Reduced costs
• raw materials, energy, water
• storage and handling
• waste disposal
• health and safety
• Regulatory compliance
• Improved efficiency
• Improved corporate image
• Economic barriers

• Technical barriers

• Regulatory barriers
• Use higher purity materials
• Use less toxic raw materials
• Use non-corrosive materials
• Convert from batch to continuous process
• Improve equipment inspection & maintenance
• Improve operator training
• Improve supervision
• Improve housekeeping
 Improve material tracking and inventory control
• avoid over-purchasing
• inspect deliveries before acceptance
• make frequent inventory checks
• label all containers accurately
• ensure materials with limited shelf-life are used
by expiry date
• Install computer-assisted inventory control
 Alternative approaches
• Participants from different industry sectors
Ex: Companies on an industrial estate, members of
Green Business Club
• Participants within a single industry sector
Ex: Via a trade association

 Common themes
• Specialist consultant to manage programme
• Facilitated discussion and dissemination
• Shared experiences
• Encouraging replication
• A systematic and ongoing effort to reduce waste
generation
• Must be tailored to specific company needs and
practices
• 3 main phases
• planning and organisation
• conducting a waste audit
• implementing, monitoring and reviewing
• Obtain management commitment

• Establish programme task force

• Set goals and priorities

• Establish an audit team


• Inspect the site

• Identify different processes undertaken on site

• List processes and obtain as much information


as possible on the process
 Account for all the material flows into each individual
process
• materials
• energy
• water

 Make sure all inputs are accounted for in detail


Example: kg of raw materials, kilowatts of electricity,
litres of water

 Make sure figures are on same basis


Example: annual, monthly, weekly inputs
 Identify and quantify all process outputs
• primary products
• co-products
• waste for re-use or recycling
• waste for disposal
 Using data acquired during the waste audit,
make preliminary evaluation of the potential for
waste minimisation

 Priorities options for implementation


 Conduct feasibility analysis of selected options

◦ Technical considerations
• Availability of technology
• Facility constraints including compatibility with
existing operation
• Product requirements
• Operator safety and training
• Potential for health and environmental impacts
◦Economic considerations
• Capital and operating costs
• Pay-back period
• Prepare Action Plan
• Identify resources
• Implement the measures
• Evaluate performance
• There are a number of good reasons for minimising
waste - source reduction comes at the top of the
waste hierarchy
• Factors which influence waste minimisation include
regulations, technological feasibility, economic
viability and management support
• There are both incentives and barriers; some
opportunities widely applicable - and valuable
experience from demonstration projects
• Guide to implementing a company waste
minimisation programme and conducting an audit
 Due diligence is relevant in all areas of business
and is used to identify liabilities.
 Some may be obvious, while others can be
hidden.
Ex: Sometimes purchasers and funders pay
unforeseen costs due to unrecognised liabilities that
have been inherited via a purchase
 EDD assessment will identify the current conditions of
a business or site and determine any liabilities or non-
compliance that may inherit through an acquisition

 Excellent way to understand the current environmental


performance of a potential investment and its
associated environmental risks and be prepared for
anything need to deal with as part of the purchase

 Gives idea on how EDD audit would work, what


outcomes should be expected and why it is important
to have an audit done if looking at business or land
purchase.
 An audit will usually start out with meetings with key
personnel within the organisation, progressing to a site tour
and inspection
 For multiple sites, a representative sample will be audited
while taking into account location and on site activities.
 Review of key documentation and data will take place to
give an overall picture of the potential investments
environmental situation.
 Audits obviously vary depending on the size of the
organisation, current and historical activities and
sometimes on the industry in which the organisation
operates.
 Concerns in audit - land, air and water emissions,
environmental permitting concerns, waste management, oil
and chemical storage and statutory nuisances in addition to
any site or organisation specific concerns
 Following audit, a report will be prepared.
 Report will give idea of what is happening in a
business or on a site by evaluating the current
environmental risks or any legal non-conformities
 Focus on three broad areas; legal compliance,
barriers to growth and a determination of clean up
liabilities and costs.
 Include any land or water contamination and any
impending or required permitting requirements.
 If any pollution has been identified, report will
conclude with an estimation of any clean up
required to return the land to its original state.
 The EDD report will show up any potential
problems and some of it may need to be dealt
soon
 The Environmental Damage (Prevention and
Remediation) Regulations, the ‘polluter pays’
principle is set out in the law.
 Its purpose is to prevent and repair any
environmental damage caused by industrial
activities, regardless of the size of the company.
 Many are unaware that when purchasing a new
business or land, may inherit with existing
environmental issues, illegalities and clean up
liabilities.
 For example, a commercial property may be polluting
the local environment. Once a purchase has gone
through, if this pollution is discovered and the original
polluter cannot be found or it cannot be proven that a
previous occupier caused the pollution, the current
owner or occupier, in this case the purchaser will be
liable. These costs can vary widely but will likely
include clean up and remediation of any damage. As
another example, you could purchase a business that
requires an Environmental Permit but has historically
been operating without one. Upon purchase, you
wouldn’t know that a permit is required and would
therefore be operating illegally. This means you are
liable for fines but even if you are not prosecuted, you
would still need to apply for an Environmental Permit
which is costly and time consuming and, if not
granted, you will need to cease or significantly change
your operations
 Environmental matters are becoming increasingly
important and are being more heavily regulated with
stricter laws and regulations and more severe
penalties for breaching the requirements
 Poses a risk for organisations, especially if not aware
of requirements.
 EDD is a way of being more aware of risks so can be
managed as part of wider business strategy
 EDD is also often requested by financial institutions,
lenders and stakeholders - investment is viable.
 Being aware of risks means need to mitigate against
it, which can be costly, prosecution, fines and the
devaluing of investment
 According to resource conservation and recovery
Act, 1976

Hazardous waste means a solid waste or combination of


solid waste, which because of its quantity, concentration,
or physical, chemical, or infectious characteristics may,
a) cause or significantly contribute to an increase in
mortality or an increase in serious irreversible, or
incapacitating reversible illness
or
b) pose a substantial present or potential hazard to human
health or the environment when improperly treated, stored,
transported, or displayed of or otherwise managed
To identify a given waste as hazardous or not, the EPA
selected following four characteristics

1. Ignitability

2. Corrosivity

3. Reactivity

4. Toxicity
 This characteristic is used to define a waste as
hazardous, if it causes fire during transport,
storage, or disposal

 All ignitable substances coming under this


definition are assigned EPA HW D-001

 A solid waste sample is considered to be ignitable


if it exhibits the following characteristics
• An aqueous solution (liquid) containing less than 24
percent alcohol (v/v) & has a flashpoint of 60o C
(140 º F) or less
• A solid that causes fire through friction, absorption
of moisture or spontaneous chemical reaction
• When ignited it burns vigorously and persistently to
create a hazard
• A compressed ignitable gas and an oxidizer

Ex: Waste oils and used solvents


• Corrosivity indicated by pH is an identifying
characteristic of a Hazardous Waste

• Waste with high/low pH can react dangerously


with other wastes or cause toxic contaminants to
migrate from certain wastes

• A solid waste with the following properties is said


to be corrosive and classified as D-002
• It is an aqueous solution with pH less than 2 or >
12

• A liquid corroding steel at the rate of 6.35 mm/year


at a test temperature of 55oC

 Example: Acidic wastes and used pickle


liquor (steel industry)
• A substance is defined as reactive if it exhibits any of the
following characteristics and classified as D- 003
• Normally unstable and readily undergoes violent
changes without detonating
• Reacts violently with air or water or forms explosive
mixture with water
• It also includes wastes that emit toxic fumes, gases,
vapors or fumes when mixed with water & materials
capable of posing danger to the human health or the
environment
• Causes detonation or explosive reaction if
subjected to strong initiating force (e.g.
pressure) or if heated under confinement

• Undergoes explosive decomposition or reaction at


standard temperature & pressure

• Poses an unreasonable risk to health, safety


and property during transportation under specific
conditions of packing defined by 49 CFR 172:101
rules
• Objective of this characteristic is to determine
whether toxic constituents in a solid waste sample
will leach into ground water when placed in a
municipal solid waste landfill

• If it leaches, then the waste is declared hazardous

• Elaborate test procedures are required to define


whether a substance is hazardous or not

• ‘Toxic’ denotes the capacity of a substance to


produce injury, while ‘hazardous’ denotes the
probability that injury will result from use of (or
contact) a substance

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