Becky Corbin, CHMM, CPEA, understands what makes a good environmental compliance or management system audit. With over 20 years of experience in environmental, health and safety compliance, she has participated in more than 100 audits and has extensive experience leading and conducting multi-media environmental health and safety compliance audits for a variety of clients, including industrial /manufacturing facilities, municipalities, utilities, universities, and hospitals. Becky also specializes in assisting clients with a wide range of environmental, health, and safety compliance needs, including program and management system development, training, reporting, plan writing, and permitting. She is a Principal and Project Manager on Woodard & Curran’s compliance services team.
It should be noted that while the focus of this interview is environmental audits and compliance, the ideas and practices discussed here could also be applied to health and safety programs.
What are the benefits of an environmental compliance audit?
“An environmental compliance audit is really a risk management tool. By operating in a non-compliant manner, facilities risk employee safety, environmental incidents, regulatory agency violations and fines, operational interruptions, and brand damage due to negative publicity. Audits provide an opportunity to minimize these risks by identifying gaps in environmental programs and best management practices that can be implemented to help a company meet its regulatory obligations and operate as a good corporate citizen.”
What is common among the best-managed facilities?
“A key element among most facilities with well-managed environmental programs is a solid management system. Maintaining compliance and effective environmental programs can be a challenge for any company, but without a system to track requirements, assign responsibilities, promote communications, involve management, evaluate programs, and establish goals and metrics, it can be significantly more difficult. A management system provides the necessary framework to achieve and sustain compliance and move programs “beyond compliance” with continuous improvement.”
What challenges or obstacles to maintaining compliance are common in any setting?
“Instilling the idea that compliance is everybody’s responsibility can be difficult. While it will vary depending on the size of a facility and the type of business, possibly dozens, if not hundreds or thousands of employees could conduct regulated activities every day. It is not possible for the dedicated environmental staff to be responsible for that entire scope of activity. Environmental compliance should be viewed as part of doing business, just as quality is, and be incorporated into facility operations.”
Why hire an outside auditor at all?
“There are several reasons why it makes sense to utilize an outside auditor to perform an evaluation of a facility. First of all, the saying “you don’t know what you don’t know” certainly applies. Internal environmental staff may do a great job managing the environmental obligations they are aware of, but if there are applicable requirements they don’t know about, there will be compliance gaps. Also, in-house environmental staff may not have the time necessary to keep up with regulatory changes or the breadth of expertise to fully understand all the technical aspects of every environmental program. Finally, sometimes we can fail to see issues right in front of us because we are accustomed to seeing them every day. Outsiders can view the operations with fresh, unbiased eyes.”
Why should someone choose an auditor with a CPEA certification?
“The Certified Professional Environmental Auditor (CPEA) certification provides some assurance on the qualifications and experience of an auditor. In order to receive the CPEA certification, an auditor must meet educational, professional, and audit experience requirements; participate in training; provide character references; and pass a written examination that demonstrates competency in a wide range of environmental programs and audit best practices. CPEAs are also expected to uphold a high standard of professional ethics. By utilizing a CPEA, a company can be confident of the technical and procedural expertise of the auditor.”
What did you learn thorough the CPEA certification process?
“I really appreciated the strong emphasis on ethics as I was reviewing materials in preparation for the CPEA exam. The CPEA certification, in addition to several other environmental health and safety certifications, is issued through the Board of Educational, Health & Safety Auditor Certifications (BEAC). BEAC has established a Code of Ethics and Standards of Conduct for auditors in order to provide guidelines for exercising honesty, objectivity, and diligence in carrying out audit responsibilities. While technical expertise is an obvious requirement for a qualified auditor, an appreciation for ethics and standards of conduct is critical to maintain the integrity of the audit process.”
What kind of continuing professional development is required for CPEAs?
“CPEAs are expected to update their knowledge and skills on auditing standards and techniques, as well as their technical knowledge of regulations. Every two years CPEAs must demonstrate continuing professional development by submitting documentation of 40 hours of relevant qualifying activities, which may include auditing, training, conference attendance, publications, presentations, and volunteer work.”
What level of involvement should facility staff have in the audit?
“Staff involvement is key to a successful audit on several levels. First of all, auditor access to employees with knowledge of regulated facilities and operations is necessary to determine what regulations are applicable and to evaluate whether activities are carried out in compliance with those regulations. An auditor can only tell so much simply by observing an area; it is also necessary to interview employees about their work practices to understand whether programs are properly implemented. Employee interviews and audit participation also can become an educational opportunity for employees and help them understand how their actions impact environmental compliance. And it can’t be overstated that visible management support for the audit activities is an effective demonstration of the significance a company places on environmental compliance.”
What makes a successful audit?
“It is important to understand that the number or severity of findings does not determine the success of an audit. A handful of relatively minor findings does not necessarily signify a “good” audit. The goals of an audit are to identify regulatory requirements, evaluate programs and facilities, recognize what aspects are compliant and functioning well, and identify opportunities for improvement. To those ends, a successful audit is one in which necessary information, facilities, and resources are made available in order to conduct a thorough evaluation and in which facility staff are cooperative and engaged. If environmental programs and compliance status are improved as a result of an audit, the audit was a success.”
When is the right time to conduct an audit?
“There can be a number of “right times” to conduct an audit, depending on the particular circumstances of a facility. A change in facility ownership or in responsibility for environmental program management can be the perfect time to review the programs, identify deficiencies, and establish a baseline. Another good time for an audit can be after a new or revised program has been implemented in order to evaluate its effectiveness. Finally, many companies conduct routine surveillance audits on a periodic basis to help ensure programs stay on track, to identify facility or operational changes that could trigger new regulatory requirements, and to ensure that applicable regulatory changes are incorporated into facility programs.”
To learn more about Woodard & Curran’s comprehensive environmental and health and safety compliance and auditing services, contact Becky Corbin at bcorbin@woodardcurran.com or (315) 400-5373.
