Module-4

ENVIRONMENTAL AUDIT
 Environmental Audit:

Environmental management system audits as per ISO 19011- – Roles

and qualifications of auditors - Environmental performance
indicators and their evaluation – Non conformance – Corrective and
preventive actions -compliance audits – waste audits and waste
minimization planning – Environmental statement (form V) - Due
diligence audit.
 Environmental management system audits
An Environmental Management System (EMS) Audit refers to a systematic
and documented verification process of objectively obtaining audit evidence to
determine whether an organization’s EMS conforms to the audit criteria and
communicating the results of this process to the client.
 The objectives of a typical EMS audit include:
 Determining conformance of an auditee's EMS with the EMS audit criteria
 Determining whether the auditee's EMS has been properly implemented and
maintained
 Identifying areas of potential improvement in the auditee's EMS
 Assessing the ability of the internal management review process to ensure the
continuing suitability and effectiveness of the EMS
 Evaluating the EMS of an organization where there is a desire to establish a
contractual relationship
Principles of Auditing

 Integrity: The foundation of professionalism

 Fair presentation: The obligation to report truthfully and accurately
 Due professional care: The application of diligence and judgement in auditing
 Confidentiality: security of information
 Independence: the basis for the impartiality of the audit and objectivity of the
audit conclusions.
 Evidence-based approach: the rational method for reaching reliable and
reproducible audit conclusions in a systematic audit process
Steps to be followed in auditing
1.Initiating the audit

When an audit is initiated, the responsibility for conducting the audit remains with the
assigned audit team leader until the audit is completed

⚫ Establishing initial contact with the auditee: The initial contact with the auditee for the
performance of the audit can be informal or formal and should be made by the audit team
leader.

⚫ Determining the feasibility of the audit: The feasibility of the audit should be
determined to provide reasonable confidence that the audit objectives can be achieved.
2.Preparing audit activities

⚫ Performing document review in preparation for the audit: The relevant management
system documentation of the auditee should be reviewed

⚫ Preparing the audit plan: The audit team leader should prepare an audit plan based on
the information contained in the audit programme and in the documentation provided by
the auditee

⚫ Assigning work to the audit team

⚫ Preparing work documents: The audit team members should collect and review the
information relevant to their audit assignments and prepare work documents, as
necessary, for reference and for recording audit evidence
3.Conducting the audit activities

⚫ Conducting the opening meeting: An opening meeting should be held with the auditee’s
management and, where appropriate, those responsible for the functions or processes to be
audited.

⚫ Performing document review while conducting the audit.

⚫ Communicating during the audit: During the audit, it may be necessary to make formal
arrangements for communication within the audit team, as well as with the auditee, the
audit client and potentially with external bodies.

⚫ Assigning roles and responsibilities of guides and observers: Guides and observers (e.g.
regulator or other interested parties) may accompany the audit team
⚫ Collecting and verifying information: During the audit, information relevant to the audit
objectives, scope and criteria, including information relating to interfaces between
functions, activities and processes should be collected by means of appropriate sampling
and should be verified.

⚫ Generating audit findings: Audit evidence should be evaluated against the audit criteria
in order to determine audit findings.

⚫ Preparing audit conclusions

⚫ Conducting the closing meeting: A closing meeting, facilitated by the audit team leader,
should be held to present the audit findings and conclusions
4. Preparing and distributing the audit report
⚫ Preparing the audit report: The audit team leader should report the audit
results in accordance with the audit programme procedures.
⚫ Distributing the audit report: The audit report should be issued within an
agreed period.
5. Completing the audit
• The audit is completed when all planned audit activities have been carried
out, or as
otherwise agreed with the audit client
6. Conducting audit follow-up
• The conclusions of the audit can, depending on the audit objectives, indicate
the need for
corrections, or for corrective, preventive or improvement actions
Roles And Qualifications Of Auditors

EMS auditors should be trained in auditing techniques and management

system concepts. Familiarity with environmental regulations, facility operations, and
environmental science is a big plus, and in some cases may be essential to
adequately, assess the EMS.
As a guidance standard, 14012 can only recommend such qualifications, and the key
is to ensure the audit team is familiar with the EMS that they are responsible for, and
not all other areas of environmental science or regulations. Secondly, it is understood
that no single individual may have all of these qualifications, hence the concept of
the audit team
Traits of a good auditor:
⚫ Independent (activity being audited)
⚫ Impartial
⚫ Tactful
⚫ Attentive to detail
⚫ Objective
The following the directions of and supporting the lead auditor;

⚫ planning and carrying out the assigned task objectively, effectively and efficiently
within the scope of the audit;
⚫ collecting and analyzing relevant and sufficient audit evidence to determine audit
findings and reach audit conclusions regarding the EMS;
⚫ preparing working documents under the direction of the lead auditor;
⚫ documenting individual audit findings;
⚫ safeguarding documents pertaining to the audit and returning such documents as
required;
⚫ Assisting in writing the audit report
Environmental performance indicators and their evaluation

Environmental Performance Indicators provide information that helps

evaluation and decision making within organizations that engage in
environmental efforts.

⚫ The first objective of environmental performance indicators is to measure and

evaluate environmental burdens, environmental problems that need to be solved

⚫ The second objective is to provide a common foundation of information

between an organization and interested parties

⚫ The third objective is to provide a common foundation of information for

macro-level environmental policies of the national and local governments.
Types of environmental performance indicators ISO standard describes
two general categories of indicators for EPE:
⚫ Environmental Performance Indicators (EPIs); and
⚫ Environmental Condition Indicators (ECIs).

There are two types of Environmental Performance Indicators:

⚫ Management Performance Indicators (MPIs)
⚫ Operational Performance Indicators (OPIs)
Examples of performance indicators and metrics1
Objectives and Benefits of an Environmental performance evaluation
(EPE)
1. Better understanding of an organization’s impacts on the
environment
2. Providing a basis for benchmarking management, operational and
environmental performance,
3. Identifying opportunities for improving efficiency of energy and
resource usage
4. Determining whether environmental objectives and targets are
being met
5. Demonstrating compliance with regulations
6. Determining proper allocation of resources
7. Increasing the awareness of employees, and
8. Improving community and customer relations
Environmental Performance Evaluation (EPE) is “an internal process
and management tool designed to provide management with reliable
and verifiable information on an ongoing basis to
The steps of this ongoing process are the following:
1.Plan
⚫ planning EPE;
⚫ selecting indicators for EPE

2 Do: Using data and information which includes:

⚫ collecting data relevant to the selected indicators;
⚫ analyzing and converting data into information describing the organization’s Environmental performance;
⚫ assessing information describing the organization’s environmental performance in comparison with the
organization’s environmental performance criteria;
⚫ Reporting and communicating information describing environmental performance.

3. Check and Act: Reviewing and improving EPE.

Environmental Performance Evaluation (EPE) is “an internal process and
management tool
designed to provide management with reliable and verifiable information on an
ongoing basis to
determine whether an organization’s environmental performance is meeting
the criteria set by the management of the organization”.

Environmental Performance Evaluation (EPE) is an internal management process

that uses indicators to provide information comparing an organization’s past
and present environmental performance with its environmental performance
criteria. EPE, as detailed in this International Standard, follows a “Plan-Do-
Check-Act” management model. The steps of this ongoing process are the
following:
Nonconformance – corrective and preventive actions No

EMS is perfect when system deficiencies are encountered organization will need a process to
ensure that:

⚫ Problems including nonconformities are investigated

⚫ Root causes are identified

⚫ Corrective actions are identified and implemented

⚫ Corrective actions are tracked and documented.

EMS nonconformities and other system deficiencies should be analyzed to detect patterns or
trends. Identifying these trends will allow you to anticipate and prevent future problems.
“Root cause analysis” is a process by which you can identify causes and preventive
actions.
Example: If a spill occurs several times in your raw material transfer area, you would
attempt to identify the root cause of the spill occurring so that you could address the
cause and prevent the spill in the future
What is a Major Non-Conformance?
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
What is a Minor Non-Conformance?
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
What are Corrective and Preventive Actions?

➢ 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 they
happen (e.g., improved maintenance procedures)

➢ Effective preventive actions are a key to CONTINUAL IMPROVEMENT

ISO 14001 Non-Conformance, Corrective and Preventive Action says:

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.
ISO 14001 Non-Conformance, Corrective and Preventive Action says:

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.

Steps to Identify and Correct Non-Conformance

➢ 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
Non-Conformance Investigation Example
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
 Principles of Corrective and Preventive Action
 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
 Fix deficiencies in the system, not just symptoms of the problem
Compliance audits

 An Environmental Compliance Audit is an investigation of the compliance status of a facility and/or the
extent of environmental liability.
 This process is a systematic, documented evaluation of a facility, focusing on current operating and
administrative procedures and processes.
 An environmental compliance audit can also be used to determine whether an existing environmental
management system is effectively:

⚫ Maintaining compliance
⚫ Identifying deficiencies
⚫ Taking corrective actions

 Environmental compliance audits are thorough inspections and reviews of facilities to ensure a company
or site is meeting environmental regulations.
 An environmental compliance audit may include a review of compliance with local, state or federal rules
as well as internal company policies.
 A regulatory compliance audit may incorporate all media, including air, soil, water, energy, noise and
waste. Or the scope may consist only of an environmental site assessment for one regulated area, such as
soil
 Each audit is custom designed for an individual facility to ensure environmental regulation
compliance specific to that site.

 Environmental compliance audit allows a company to identify and address any existing or potential
environmental issues before they become legal issues or lead to regulatory fines and penalties.

 Educating the company’s staff on environmental compliance is also a part of the audit.

 Environmental compliance audits focus on a company’s operations and systems. A customized, detailed
checklist-type protocol is typically used to conduct the audit.

 Environmental compliance consulting also may include questionnaires, site visits, and records reviews,
interviews with staff, and comprehensive facility inspections and compliance reviews.

 Conducting a compliance audit not only lowers the risk of violating environmental regulations, but also
demonstrates a company’s commitment to continually improving the environment
Waste audits

 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.
 A waste audit is a thought-out process that is used to determine the amount and types of
Organizations conduct waste audits to minimize the organization's waste impact on the
environment.

 Organizations conduct waste audits voluntarily and as mandated by local, state and federal laws.

A waste audit will help organization to clearly, identify their 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 accreditation.

Process of Waste Audit:

⚫ A waste audit is a process used to calculate the type and amount of waste generated by an
organization. Any size organization can perform this type of 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 theorganization more effective at
reducing waste management costs by educating staff about proper waste disposal and making better
use of natural of waste produced by a company 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 th
is 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 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
Waste Minimization Planning

Waste minimization can be defined as "systematically reducing waste at source". It means:

 Prevention and/or reduction of waste generated

 Efficient use of raw materials and packaging

 Efficient use of fuel, electricity and water

 Improving the quality of waste generated to facilitate recycling and/or reduce hazard

 Encouraging re-use, recycling and recovery

The following are the techniques:

 Waste Reduction at source – this can be achieved by changing or modification of production process and/or
equipment’s used, with assurance that product quality is not affected.

 Product or raw materials substitution involves substitution of raw materials with that of less toxic substances
and can produce the same product quality but of less residual unwanted by-products.

 Process change, modification and control includes the use of latest technology involving new equipment or the
process itself. Its application, however, is process-specific and shall be carefully studied before being
implemented for selection of the best and the most acceptable alternatives.

 Good housekeeping practice is the key aspect in keeping waste minimization program a success and has a
minimum capital requirement and yet provides the highest return on investment. This can be easily
accomplished thru awareness programs & campaigns of company staff on the benefits of waste generation and
its control.

 This includes proper waste segregation & waste classification to determine its quality, proper storage, and
determining its value or usability. On the part of the management, regular waste audit for reconciling what goes
in and what out are useful tool in determining the overall benefits of good and realistic housekeeping programs.
 Waste Re-Use and Recycling – is the practice of recovering usable component of a declared
waste for subsequent use in other purpose or sale either with or without pre-treatment. Generally,
recycled materials can either be used in the same service from which it was generated or in an
entirely different premises, activities or purpose with consideration on possible mis-use, its effect,
the efficiency and safety of the receiver or user.

Treatment of Waste – eliminates the toxic content of the waste stream, reduces the risk of
pollution and health of the public, and increases its acceptability for discharge into the environment
for its intended use. This also provides incentive to the user as it enhances the quality of waste and
increases the potential for recycling
Benefits of Waste Minimization Practice:
Waste minimization practice benefits not only the company or the waste generator, but the government
regulatory agency as well.

This includes:
• Increase of production, but lessen the waste generation;
• Saving money by reducing waste treatment & disposal cost, raw material purchases and
other operational costs including storage;
• Optimize use of resources (like water);
• Enhance public and worker's health and safety;
• Improve environmental performance, regulatory compliance & meeting to any national
waste minimization goals;
• Extend the useful life of landfills and disposal sites;
• Reduce potential environmental liabilities; and
• Promotes good public image on environmental protection.
4.7 Due diligence audit
 Due diligence is the investigation or exercise of care that a reasonable business or person is
expected to take before entering into an agreement or contract with another party.

 Due diligence is an investigation or audit of a potential investment or product to confirm all facts,
such as reviewing all financial records, plus anything else deemed material. It refers to the care a
reasonable person should take before entering into an agreement or a financial transaction with
another party.

 A Process used to identify environmental problems associated with a piece of property prior to
purchase. The scope of property transfer assessments often is much broader and focusses more on business risks
and liabilities as opposed to regulatory compliance.
 Enforcement and Compliance history online (ECHO) A web based tool that provides access to
compliance and enforcement for opportunity 800,000 EPA regulated facilities. ECHO allows users to
find permit, inspection, violation, enforcement action, and penalty information covering the past two
years.

 The data in ECHO are updated monthly. Effects Refers to changes, actual or potential, caused by a
chemical, activity, or process as it comes into contact with humans or the environment. Effluent Any
gaseous or liquid waste fluid emitted by a source.

 A discharge from an exit is relatively self contained, such an industrial smokestack or a sewage
treatment plant. Often referred to as the source of pollution or pollution itself, pollutant discharges into
water

 Emergency response Responses to incidental releases of hazardous substances where the substances can
be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate
release area, or by maintenance personnel are not considered to be emergency responses within the
scope of this standard. Responses to releases of hazardous substances where there is no potential safety
or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency
responses
Environmental Due Diligence(EDD) is the assessment and management of environmental
liabilities and risks.

 Environmental Due Diligence is both a legal and technical exercise – an action of analyzing your
organization’s site or a site your organization is looking to acquire. It is often demonstrated by a formal
assessment of the organization and land to identify any existing or previous environmental conditions
and/or contaminations and quantify financial and legal risks.

 The environmental assessment which is a part of a due diligence process mainly aims at identifying any
claims or liabilities generated by environmental degradation, such as potential soil and groundwater
contamination resulting from current or historical activities performed on the site which is subject to the
transaction process.

 Also, another objective of an environmental due diligence (EDD) is the estimation of associated
remediation costs, which may affect the closing of the transaction; if such costs are identified, they can
serve as an efficient negotiation tool for the parties involved in the transaction and they can ultimately
be turned into commercial advantages.
Environmental statement: form 5

 In today’s world every industry is optimizing their Sources, equipment’s, processes to face
increasing competitions are forced to minimize Environmental pollution. There is need of
pressure on pollution contributing industries to optimize their production by improving
production technologies.

 Environmental statement is process of self-inspection for improvement in processes and

reduction in waste over the last year.

 The only mandatory process in Environmental Statement is to fill up the Form V and submit it
to Pollution Control Board. If you notice Form V there are fields where industry needs to put
their last year’s Numbers with Current Years Numbers to identify where they stand.
Environmental Statement Submission Date

 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.

 Information Collected through Environmental Statement Form V 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

Environmental Statement Form V Filling Process

There are total Nine Section in Environmental Statement Form V.

 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.

 Part C 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.

 Part D This part to measure hazardous waste from processes and from pollution control facilities

 Part E This part is to measure solid waste generated by industry. Also details like quantity
recycled, sold and disposed

 Part F Any new practices adopted to reduce hazardous waste

⚫ Part G Impacts of pollution control measures on natural resources and with cost of
production.
⚫ Part H Additional investment / process / measures to minimization or prevention of
pollution.
⚫ Part I In this part other information / initiatives to improve quality of environment needs to be given.
Whenever Part C, indicates high variation then Part H (i.e. additional investment proposals for
environmental protection including abatement of pollution) should be taken more seriously
PART-B
Water and Raw Material Consumption:
i. Water consumption in m3/d
Process: 5710
Cooling: 700
Domestic: 290
PART – F

Please specify the characteristics (in terms of concentration and quantum)ofhazardous as well as solid wastes
and indicate disposal practice adopted for both these categories of wastes. Please refer Annexure A to Form V

PART- G

Impact of the pollution control measures taken on conservation of natural resources and consequently on the
cost of production. Please refer Annexure B to Form V

PART – H
Additional measures/investment proposal for environmental protection including abatement of pollution.
PART - I MISCELLANEOUS: Any other particulars in respect of environmental protection and abatementof
pollution
Annexure A to Form V

PART F (Please specify the characteristics (in terms of concentration and quantum) of hazardous as well as
solid wastes and indicate disposal practice adopted for both these categories of wastes.) 1. Following
hazardous waste from the plant are disposed in safe manner, according recommended practices without any
nuisance to environment.
Annexure B
to Form V

 PART G (Impact of the pollution control measures taken on conservation of natural resources and
consequently on the cost of production.)

 Water being very scarce commodity, maximum efforts are made to conserve it. One of the
important technologies installed in the captive power plant is “Air cooled
Condensers” in the place of conventional water-cooled condenser. This facilitates our plant to save
water loss due to evaporation in the cooling tower.

 The total investment for Air cooled condenser is ₹ 16 crore. Due to use of Air-Cooled Condenser in power
plant there is saving in water consumption to the tune of 5000 m3/ day