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enviromental auditing

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Ricardo Castillo

on 23 March 2015

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Transcript of enviromental auditing

enviromental auditing
Ricardo Castillo
Leidy Ramos

environmental auditing started in the late 1970s in
response to the wave of high-impact environmental

Companies unable
to keep track of a rapidly expanding regulatory landscape
were hit with notices of violation, enforcement actions, and
citizen suits.

The answer for many was environmental auditing—the
process of identifying all applicable legal requirements and
related objectives for a facility or group of facilities, conducting
an inspection or “audit” of a company’s compliance with
them, and identifying all noncompliance.

By the early 1980s forward-thinking companies had established
internal environmental auditing or “assessment” groups,
either as part of an environment, health, and safety (EH&S)


generalities
The goal was to reduce potential liability and improve
EH&S performance by establishing programs to identify all of
a company’s legal obligations and objectives and ensure on going compliance.

These included regular auditing of the company’s
facilities, typically at three- or four-year intervals or more
frequently as needed, based on risk-based prioritization

After the audit, a good corrective-action plan included a
review of frequently occurring and repeat violations as well as
a “root cause” analysis so that the underlying conditions giving
rise to noncompliance were addressed.

generalities
By the early 1990s companies were beginning to refer to
their programs as “environmental management systems” or“EMSs.”

The U.S. Environmental Protection Agency (EPA) recognized that environmental auditing programs led to heightened awareness and compliance with environmental requirements.

generalities
EPA set forth what it viewed as the basic elements of an effective
auditing program:

(1) explicit top-management support for environmental auditing and a commitment to follow up on audit findings
(2) an environmental auditing function independent of audited activities
(3) adequate auditor team staffing and training
(4) explicit audit program objectives, scope, resources, and frequency
(5) a process that collects, analyzes, interprets, and documents information sufficient to achieve audit objectives
(6) procedures to prepare candid and clear

EPA (enviromental protetion agency)
EPA (enviromental protetion agency)
On July 1, 1991, DOJ issued a policy document
entitled “Factors in Decisions on Criminal Prosecutions
for Environmental Violations in the Context of Significant
Voluntary Compliance or Disclosure Efforts by the Violator.”

Environmental Site Assessment
(ESA)
The ESA includes not only a physical site assessment but an interview of knowledgeable company employees, a search of the land records, and utilization of databases to determine whether there is evidence

Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process

There are nine conditions a company must satisfy to gain
the benefits of this policy.

The basic elements required for an EMS under
ISO-14001 are as follows:

basic features (ESA)
1. Environmental Policy. A policy
2. Environmental “Aspects.”
3. Identification of Legal and Other Requirements.
4. Objectives, Targets, and Programs
5. Resources, Roles, Responsibility, and Authority.
6. Competence, Training, and Awareness
7. Communication.
8. Documentation.
9. Document Control.

basic features (ESA)
10. Operational Control.
11. Emergency Preparedness and Response
12. Monitoring and Measurement.
13. Compliance Evaluation.
14. Nonconformity, Corrective Action, and Preventive Action.
15. Control of Records.
16. Audits. Objective, impartial, and regularly
17. Management Review.

thanks
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