Overview of Environmental Health & Safety Audits

Are Environmental, Health & Safety Audits Necessary?

There are no environmental, health or safety (EHS) laws that require comprehensive audits. However, audits are essential for proper EHS management. One of the most important aspects of ensuring environmental compliance is routine, detailed Environmental Audits. It is highly unlikely that any company complies fully or at all times with all EHS laws. Furthermore, laws, operations, and employees constantly change.

What Is To Be Gained From An Audit?

Environmental Audits are an essential part of an effective and comprehensive EHS Management Program. While such audits do not guarantee immunity from civil and criminal liabilities, an appropriate audit program can help insulate managers and executives from such threats. In fact, EPA offers some regulatory relief for facilities with "self policing" programs in place (“Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations”, 65 FR 19618, 04/11/00). However, the impact of penalties and enforcement actions is not the only reason for conducting audits. Poor environmental practices, whether intentional or not, can result in:

• Poor employee morale
• Adverse publicity
• Inefficient operations
• Diluted asset values
• Natural resource damages
• Personal injuries
• Criminal prosecution
 

Risk of Audit Disclosure

There has been much discussion about the risk of disclosing information obtained during audits. There are no guarantees that the findings will never be disclosed to governmental authorities. However, there are precautions that can be taken in performing audits that can minimize risks of such disclosure. In fact, some states have enacted environmental audit privilege laws to protect confidential EHS audits and  shield them from disclosure in administrative and judicial proceedings. Additionally, steps can be taken to further minimize the risk of disclosure, such as knowing when to prepare written reports, what a written audit report should contain, and who should actually request the audit. We know how to handle these situations and can advise you on appropriate steps when conducting Environmental Audits.

Experience and Approach

We provide Environmental Auditing services for many industrial and governmental clients. Experienced in all aspects of environmental, safety, and health regulations, we provide a detailed evaluation of compliance with applicable state and federal regulations, allowing the facility to find and correct deficiencies before they are discovered by regulatory agencies. The results of such audits are extremely beneficial. Timely discovery and correction of deficiencies frequently mitigate, or even eliminate, regulatory penalties as well as avoid negative public relations.

Our experienced team of professionals knows and understands the many unique aspects of compliance with extremely complex regulations. Our staff constantly reviews regulations and enforcement actions by regulatory agencies to monitor how individual standards are being interpreted and enforced. We maintain a complete library of environmental regulations to assist us in this effort.

We have performed Environmental Audits for a wide variety of industries including:

• Textile
• Chemical Manufacturing
• Electroplating
• Pharmaceutical
• Kraft Paper Mills
• Steel Mills
• RCRA TSD Facilities
• Metal Finishing
• Electrical Component Manufacturing
• Food Processing
• Petroleum Facilities

Familiar with the sensitive nature of Environmental Audits, we are trained in appropriate methods for conducting audits while maintaining the confidentiality of the information collected. We routinely perform Environmental Audits through legal counsel for purposes of identifying potential problem areas and preparing for legal proceedings.