ENVIRONMENTAL PROTECTION AND MANAGEMENT- 21CV753

Module-4 Environmental Audit

• An audit is a formal review of an individual or organization's accounts or financial

situation. It can also refer to the final report of an audit.
• An environmental audit is a systematic evaluation of an organization's activities and processes
to assess their potential impact on the environment.
• Environmental auditing is a systematic, documented, periodic and objective process in
assessing an organization's activities and services in relation to: Assessing compliance with
relevant statutory and internal requirements. Facilitating management control of
environmental practices.

There are three primary types of environmental audits:

1. Compliance Audit: This focuses on whether an organization meets environmental laws.

It checks for compliance with legal requirements, permits, and licensing standards.

2. Environmental Management Audit: This examines the effectiveness of an organization's

environmental management systems (such as ISO 14001), policies, and procedures. It
evaluates how well the system manages environmental impacts and supports
sustainability goals.

3. Functional/Performance Audit: This assesses the environmental performance of specific

activities, processes, or systems within the organization. It often identifies ways to
improve resource efficiency, reduce waste, and minimize pollution.

ISO 19011

• It is guidelines for auditing management systems.

• It is a framework developed by the ISO to assist organizations in conducting audits of
management systems, including systems for quality, environmental, health and safety,
information security, and others.
• ISO 19011 was first published in 2002 and has been updated to reflect evolving auditing
practices, most recently in 2018.

Different types of Audit

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ISO 19011 is a standard designed to help companies perform audits.

When it comes to ISO standards, there are two main different types of audit:
• Internal audits (first-party)
• External audits (second-party and third-party)

First-party this is simply an internal audit.

• Internal audits are conducted by (or on behalf of) the organization itself. These audits are
typically in the context of assessing conformity, evaluating effectiveness, identifying areas
that could be improved, or as requirements for certain ISO standards specifying that internal
audits need to be carried out.
• First-party audits may also be done as a preparation for a 3rd party audit; however, first party
audits can never result in an ISO certification.

Second-party
• External audits encompass both second and third-party audits.
• Second-party audits are conducted by, or at the request of relevant interested parties outside
of the organization, like customers or contracted organizations on behalf of a customer.
• For example, a client and vendor have a contract, and goods or services are being exchanged.
Typically, second-party audits will be more formal than first-party, because they will
influence the relations with customers or other relevant interested parties.

Third-party
• Third party audits are done by independent organizations that have no vested or conflict of
interest in the organization being audited, like those that provide certification, or government
agencies.
• Customers can also request third-party audits, and this will usually be in order to verify you
conform to some specific requirements.
• Only third-party audits can be used to get ISO certified. Third-party audits may also result in
other types of registration, recognition, or licensing.

Environmental Management System Audits as per ISO 19011

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• EMS audits, when conducted according to ISO 19011, that helps organizations assess and
improve their environmental performance.

• ISO 19011 provides guidance on auditing management systems like ISO 14001, which
focuses specifically on environmental management.

• ISO 19011:2018 provides valuable information on how to improve an audit program

systematically, just as other departments in an organization are expected to improve. One
aspect of such improvement is continuously ensuring the audit program objectives are in line
with the management system policies and objectives. Organizations, in pushing for auditing
improvements, should consider the needs of customers and other interested parties.

ISO 19011 offers guidance on every step of auditing a management system or audit
program, including:

• Defining program objectives

– Ensuring to understand the specific objectives to achieve

– Making audit arrangements
– Assigning roles and responsibilities
– Defining number, scope, location, and duration of audits
– Determining criteria and specific checklists
• Completing the audits needed
– Planning and reviewing internal documents
– Collecting and verifying audit evidence
• Reviewing the results and process
– Assessing results and trends
– Conforming with audit program procedures
– Evolving needs and expectations of interested parties
– Analysing audit program records
Roles and qualifications of auditors

• Auditors play a crucial role in assessing an organization’s financial statements, compliance

with regulations, and effectiveness of internal controls.

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• Knowledge of commercial and industrial laws, because in many cases transactions and
accounts are governed by law.

• Good idea about practical business methods and office procedure in order to understand
clearly the nature of transactions.

Key Attributes of an Auditor

Roles of Environmental Auditors

1. Compliance Verification: Environmental auditors ensure that organizations

environmental regulations, such as those related to emissions, waste management, water
usage, and pollution control.

2. Evaluation of Environmental Management Systems (EMS): adhering to ISO 14001

standards.

3. Risk Assessment and Mitigation: hazards to ecosystems, and risks associated with
resource depletion or pollution.

4. Sustainability Reporting: Many environmental auditors assist in preparing sustainability

reports, which include assessments of carbon footprints, water usage, energy efficiency,
and waste reduction.

5. Assessment of Environmental Impact: They examine the organization's practices in

areas like energy consumption, waste generation, emissions, and resource use to
determine if improvements are needed to reduce the environmental footprint.

Qualifications of Environmental Auditors

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• Educational Background: Advanced degrees, such as a master’s degree in

environmental science or environmental law, can be beneficial for more complex audit
roles.

• Professional Certifications: Certified Environmental Auditor (CEA), ISO 14001 Lead

Auditor

• Experience: require 5+ years, often in a specialized sector such as energy,

manufacturing, or government.

• Knowledge of Environmental Laws and Standards

Typical Job Duties of Environmental Auditors

• As an environmental auditor, you will be responsible for the regular auditing of all
environmental policies and procedures. This involves working with an audit team
and with staff to get a good picture of how environmental compliance is being
handled. You will be responsible for:

o Selecting and managing the audit team.

o Reviewing the operations of the business being audited and determining how
environmental issues are being handled.
o Gathering data on the business operations through on-site inspections,
document reviews, staff interviews, and other methods.
o Check business records for governmental permits and requirements, safety
standards, maintenance, and inventory control measures.
o Review emergency preparedness and response procedures.
o Review management systems, environmental monitoring programs and waste
management efforts.
o Review employee training procedures and programs and the work
environment for compliance with government and corporate standards.
o Write and compile final audit reports including results of the audit and
recommendations for changes and improvement

Environmental performance indicators & their evaluation

• EPIs are metrics used to evaluate and monitor an organization’s environmental

performance across various domains such as energy use, water management, waste
generation, air quality, and biodiversity.

• Energy Performance Indicators

o Energy Consumption per Capita: Measures total energy usage divided by the
number of students, faculty, and staff.
o Evaluation: Monitor monthly or yearly energy bills and compare them per
capita. High consumption may indicate a need for energy efficiency measures.
• Waste Management Performance Indicators
o Total Waste Generated per Capita: Measures total solid waste generated
divided by campus population.

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o Evaluation: Weigh waste collected over time and calculate per capita figures.
High waste levels suggest a need for reduction initiatives, such as minimizing
single-use items.
• Water Performance Indicators
o Water Consumption per Capita: Measures water use divided by campus
population.
o Evaluation: Track water bills or meter readings, focusing on high-consumption
facilities (e.g., labs, hostel, canteen). Compare against benchmarks to identify
potential conservation efforts.

Non conformance

• Non conformance is defined as the event in which a product, service, or process does
not meet the established requirements.

• When a product, service, or process doesn't meet the standards or expectations of a company.
• For example, a company might have nonconforming procedures if they don't use the
management system correctly or follow standard operating procedures. including:
– Poor communication
– Poor documentation
– Poor training of personnel
– Poor quality materials
– Poor quality tools and equipment

Non conformance Examples :

– Waste Management: Improper disposal of laboratory chemicals, lack of segregation
for recyclable and non-recyclable waste.
– Energy Use: Excessive energy consumption due to inefficient systems or appliances
or lack of renewable energy implementation.
– Water Management: High water consumption without measures to conserve,
inadequate wastewater treatment, or failure to maintain rainwater harvesting systems.
– Chemical Handling: Failure to comply with safe chemical storage and handling
practices in labs, leading to spills, leaks.

Types of Non-conformances

• Non-conformances are typically

categorized as major or minor, based on
their severity and impact:

• Minor non-conformance: is an event that does not follow the requirements and is unlikely to
significantly impact the product’s quality, safety, or compliance.
– Using an instrument after its calibration date.
– Customer complaint that is not resolved in a timely manner.
– Release of a purchase order without prior approval.

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– Unsigned document

• Major non-conformance: is a failure to meet requirements that are likely to significantly

impact the product’s quality, safety, or compliance.
– Multiple missing or unsigned documents.
– Multiple unauthorized alterations to documents.
– Multiple violations of requirements.
– Problems that adversely affect processes or operations.
– Distributing a product that is unsafe to use.
– Contamination of a product with foreign materials.
– A serious safety hazard in the workplace.
– Complex problems that require significant effort to correct.

Non conformance Management Process

• Nonconformance management is a requirement in many regulations, standards, and

guidelines.
• A few requirements that specify nonconformance management are listed below.
– ISO 9001:2015 in Section 10.2
– ISO 13485:2016 in Section 8.3
• The nonconformance management process involves a series of steps to address and
resolve nonconformances.

The non-conformance management process involves several steps, including:

➢ Identification: Identify any areas that are not meeting the required standards,
specifications, or requirements
➢ Risk assessment: Perform a risk analysis to identify potential risks that could lead to
non-conformance
➢ Root cause analysis: Gather all information related to the non-conformance and
analyze it to find the underlying cause
➢ Corrective action: Take steps to remove the causes of the non-conformance
➢ Develop a corrective action plan: Create a plan to implement the corrective actions
➢ Monitor and follow-up: Monitor the processes and products to ensure the corrective
actions were effective

Corrective action

Below mentioned table details the type of nonconformity, source for its identification, and the
mitigation action recommended. Criterion for taking corrective action is described in the
subsequent paragraphs.

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Preventive action

Elements for which a preventive action can be implemented are similar to those described under
corrective action. One or more of the following means can be utilized to identify opportunity for
preventive action:

a) Trend analysis of element (of EMS system) wise nonconformities;

b) Trends in “no loss incidents”
c) Periodic inspection / “walk-through”
d) Suggestion from employees
e) Audit recommendations

Root-cause analysis shall be carried out for the identified / reported potential nonconformity.
Preventive actions proposed for an identified / reported potential nonconformity shall be
reviewed in the management review meetings or by the EMR for techno-commercial viability.
The respective functional heads shall implement those that are approved. Records of the results of
action taken shall be maintained.

Compliance audits

As the name implies, these audits are intended to review the site's/company's legal compliance
status in an operational context. Compliance audits generally begin with determining the
applicable compliance requirements against which the operations will be assessed. This tends to
include federal regulations, state regulations, permits and local ordinances/codes. In some cases,
it may also include requirements within legal settlements.

Compliance audits may be multimedia or programmatic. Multimedia audits involve identifying

and auditing all environmental media (air, water, waste, etc.) that apply to the
operation/company. Programmatic audits (which may also be called thematic or media-specific)
are limited in scope to pre-identified regulatory areas, such as air.
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Audits are also focused on operational aspects of a company/site, rather than the contamination
status of the real property. Assessments, studies.

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.

Environmental Compliance Audit can be simplified into three steps:

Pre-Audit: 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.

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.

Post-Audit: 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.

Auditing compliance within a management system as per ISO 19011-2018

The audit team should consider if the auditee has effective processes for:

• Identifying its statutory and regulatory requirements and other requirements it is

committed to;
• Managing its activities, products and services to achieve compliance with these
requirements;
• Evaluating its compliance status.

Waste audits and Waste minimization planning

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A waste audit is a physical analysis of waste composition to provide a detailed understanding of

problems, identify potential opportunities, and give you a detailed analysis of your waste
composition.
Or
A waste audit is a method for analyzing an organization’s waste stream. The goal is to discover
what types and quantities of waste (paper, plastic, food etc.) you produce within a given
timeframe—usually a week. Auditing also measures how much waste is recycled vs. thrown out.

A waste audit will help you clearly identify your waste generation to:

• Establish baseline or benchmark data.

• Characterize and quantify waste streams.
• Verify waste pathways.
• Identify waste diversion opportunities.
• Identify source reduction opportunities.
• Assess effectiveness and determine ways to improve efficiency of your current waste
management systems.
• Gain specific information for local government.
• Obtain detailed data on waste generation.

Waste Audit Process:

The Audit

• The data collected from the audit will identify the type of waste produced by the
organization and how the organization manages this waste.
• The audit can also make the organization more effective at reducing waste management
costs by educating staff about proper waste disposal and making better use of natural
resources. When performing a waste audit, the organization should not inform staff about
the audit prior to the completion of the audit.
• Informing staff in advance can alter waste disposal habits resulting in an inaccurate and
counterproductive audit.

Validating the Data;

Once the organization receives the data from a waste audit, the organization must validate
the data. The company must ensure that the data collected during this process is sample
representative. Additionally, the data must consider the organization over time.
If the organization had previous waste audits, the organization should compare the data
from the present waste audit to the data previously generated. Once the organization
successfully validates the data and makes sure the data is representative of the habits of
the organization, the organization can take measures to make changes to waste
management procedures.

Implementation;
Organizations may choose to implement aspects of the waste audit with the help of
different environmental agencies such as the Environmental Protection Agency or

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various state and local agencies. Environmental agencies have many resources that
the organization can use to make the implementation process more effective. Each
organization has specific waste management needs, but reduction, collection and
recycling are common tools used by organizations during the implementation process.

Monitoring and Reviewing

In many cases, the initial excitement of performing and implementing these audits
does not last long.
A monitoring and review process performed weekly, bi-monthly or monthly by the
organization can help to ensure the long-term success of changes to waste
management policies. Typically, organizations will create a waste team responsible
for this monitoring and review process.
Additionally, rotating the team members involved in the monitoring and review
process will discourage complacency and encourage organization-wide participation
in waste management changes

Identify Wastes;
The objective of this step is to estimate types of wastes and places where they are
generated. During the review, you should note existing collection and storage practices
and any other Special considerations that should be taken into account for the waste
reduction work plan.
The different types of waste that your establishment generates are to complete a walk-
through while noting the types of waste and recyclables that are generated in each
operation or area.

Estimate Waste Quantities

It is now necessary to estimate how much of each of the three classifications of waste materials
identified above that your operation generates during a specific period.

Identify Recycled Content

Recycled content can be derived from “pre-consumer” (or “post-industrial”) waste, which
is waste that is generated in the production process, e.g., trimmings from a paper
manufacturer.
Recycled content also can be derived from “post-consumer” waste, which is waste that is
generated as a result of a final consumer using a product, e.g., old newspapers or
corrugated cardboard boxes.

Waste minimization planning;

Reducing environmental impact: Effective waste management enables you to minimize

your company’s adverse effects on the environment.

Staying compliant with regulations: A robust waste management program keeps your
company in compliance with local and federal laws.

Lowering disposal costs: Many businesses wonder whether professional waste

management will be too expensive. Proper waste management services, though, can often
reduce your disposal costs.

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Ensuring worker health and safety: You want your company to maintain a safe,
comfortable working environment for employees.

Consider Your Waste Hierarchy

As you plan your waste management practices, consider implementing a hierarchy that
prioritizes sustainable processes like reusing and recycling over landfill disposal:

Reduce: Start by examining where your facility can reduce its waste generation. You
might discover that more material is coming into your facility than is necessary.

Reuse: Consider what types of waste your facility can repurpose. For instance, if you
have a construction business, find ways to reuse leftover materials from a construction
site or repurpose salvaged materials from a demolition.

Recycle: Consider what waste you can divert from your disposal stream and break down
for recycling. For instance, if you’re throwing away old electronics, look into sending
them to a specialized facility that can recycle their metals.

Recover: With a waste-to-energy program, you may also recover energy from
combusting waste.

Dispose: Generally, everything that remains after you’ve exhausted the options above
must go to a landfill. With effective waste management practices, you can often minimize
the amount of waste that falls into this category and develop strategies for responsible
disposal.

Due Diligence Audit

A due diligence audit is an internally conducted audit of a company that seeks to

ensure that the company is ready for sale.

Environmental due diligence is a legal and technical investigation conducted to satisfy certain
liability protections using state and federal environmental laws or standards. Due diligence can
also be used to develop information about environmental conditions used to allocate liability and
manage environmental risks.

Due Diligence Example:

• Conducting a property inspection before completing a purchase to assess the risk of the
investment, an acquiring company examining a target firm before completing a merger.
• A company might examine another company's financials before a merger or acquisition.
• A company might assess a target company's human capital, including their HR policies
and work culture.

Why is due diligence audit important

• A transaction backed up by a due diligence audit has a better chance of being successful.
• If something is miss during the transaction, the due diligence audit will likely bring
everything back to light.

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• It enhances the quality of the information and will therefore allow you to make a good
decision.

Environmental statement (form V)

Environmental Statement Form V is a document that industries must submit to the

pollution control board to report on their environmental impact.

Environmental Statement Form V Filling Process, This Part is to measure Pollutants Discharged
to Environment through medium Air and Water. How much in excess, an industry is releasing the
pollutants into the environment. Any new practices adopted to reduce Hazardous waste.

Notification for Environmental Statement form V Published on 28 Apr 1992 by Ministry of

Environment and Forest. As per act (Water, Air and Hazardous waste) Every Industry should
submit environmental Statement for financial year ending (i.e. 31st Mar) to concerned state
Pollution Control Board.

Environmental Statement Form V Contents

In the Environmental Statement every industry should to provide Information on Production,

Consumption of raw, Water, Pollutants discharged in environment, Solid and Hazardous waste
with their Treatment Processes.
Important things to be reported to Pollution control board are:

• If that company is reusing its by-products or waste material which results in Reduction
in consumption of Air, Water or energy.
• Production cost
• Additional Investment proposals for environmental Protection i.e. up-gradation,
Improvement in Process or New Equipment’s to reduce Environmental Pollution.

Environmental Statement Form V Filling Process

There is total Nine Section in Environmental Statement Form V. It consists

Part A: Basic Information About Company Like Name, Address, Industry Category, Production
Capacity and Date of Last Environmental Audit Submitted.

Part B: This Part is for Comparison of Water and Raw Material consumption for this financial
year to previous year.

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Part I: In this part other information / initiatives to improve quality of Environment needs to be
given.

Recommended questions
1. Give the contents of environmental statement form V
2. Explain the major and minor non-conformities that affect the efficiency of environmental
management standards in an industry

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3. What is waste audit and how do you plan waste audit in an organization
4. Write a shorts note on waste minimization planning in an industry

Outcomes
• Develop, Implement, maintain and Audit Environmental Management systems for
Organizations.
• Appreciate the elements of Corporate Environmental Management systems complying to
international environmental management system standards.

Dr. Rajesh R, VCET Puttur