ENVIRONMENTAL AUDITING

As the term implies, a detailed inventory of activities where pollution is produced is undertaken by an objective party, preferably at arm's length of the owner. It is a systematic process used to evaluate the environmental and social performance of an organization as set out in its Environmental Management System.This performance is measured against government standards, corporate policies and accepted industry practice. Audits can identify compliance problems, shortcomings in management systems and areas where risks are unacceptable. Thus, the objective of identifying problems through an audit is an important link in an EMS which requires compliance to standards to be implemented. Since the environmental auditing role is typically carried out by external consultants, company experts are available to assist in this capacity. By addressing existing pollution problems and non-compliance issues squarely, the proponent reduces risks associatied with future liability. Thus the focus can be on continuous improvement and increased efficiencies and profitability which should result from economic, social and environmental synergies.

More specifically, ISO 14011 defines an EMS audit as a systematic and documented verification process of objectively obtaining and evaluating audit evidence to determine whether an organization's EMS conforms to the audit criteria, and communicating the results to the client.  The criteria usually relates to local laws and specific environmental regulations and the requirement for compliance to the organization's policies, practices and procedures. These may include IFC or EBRD environmental and social performance standards and EHS Guidelines for international projects to ensure that local legal requirements for environmental and social impact assessment and mitigation during development are bolstered to reduce risks. The Equator Principle Banks require conformance to the IFC standards so that their investments have a reasonable chance of being accepted by the local population to gain the social license to operate, since simply acquiring  project permits does not guarantee success. In North America this is illustrated by the National Energy Board having given the green light to the Northern Gateway Pipeline project. Notwithstanding this federal approval, the difficult conditions of the Province of British Columbia  and the First Nations' rejection of the project  has resulted in the Government of Canada holding back on approving the project, pending legal challenge resolution. This due to environmental concerns related to oil spill risks in the pristine NW Pacific related to proposed oil tanker traffic increases i.e. an Exxon Valdez scenario. Similarly, the Energy East Pipeline is stalled due to communities in Eastern Canada, most notably Montreal, questioning the virtues of running 1.1 M bbl per day of dilbit through sensitive watersheds. This raises the issue of what to audit against since the Canadian Environmental Assessment Act and the National Energy Board filing requirements are apparently too narrow in scope and thus inadequate, in the eyes of intervenors. Even with the NEB's 209 Conditons of Approval the Northern Gateway project has not gained local acceptance. With the UN requirement for the informed consent of aboriginal people for major projects affecting their lands - in Canada, First Nations - the challenge is to audit a project against best international practice that will assure that the social license and informed consent of stakeholders, including First Nations and project affected people, results.  Clearly for major projects this is no easy task, so senior environmental expertise is required and is available.

Specific tasks that need to be undertaken for an environmental audit follow:

The audit scope has to be clearly set out describing the extent and boundaries of the audit in terms of factors such as the project affected area - direct footprint, adjacent area affected by access or noise and risks and regional influence - affected by the need to study alternatives and to consider effects of the supply chain and development of ancillary facilities such as waste management sites, in consultation with a broad audience. The scope should be determined by the auditor and client cognizant of regulatory financial institutions, requirements and concerns of the project affected people, so that relevant issues are addressed.

A preliminary document review includes the organization's documentation including environmental policy, manuals, studies such as ESIAs and environmental and social baseline studies supporting the EMS including environmental and social management plans. Where large gaps are noted recommendations should be made for the documentation to be produced so that the audit can be completed over time and phased to address reports, as they are produced and policies developed to address emerging issues.

An audit plan should be produced including flexibility so that the emphasis can shift during the audit and resources reallocated to suit evolving priorities. The Plan should include:

• The audit's objectives and scope;
• The audit criteria;
• Identification of the subject organizational and functional units to be audited;
• Identifcation of those responsible for the EMS and their function;
• Prioritization of EMS issues;
• Procedures for carrying out the audit;
• Time, duration, schedule and meetings required;
• Identification of audit team members;
• Confidentiality requirements, anticipated report content, format, expected date of issue and audit distribution and document retention.

Audit team assignments are then made by the lead auditor to assure that the EMS is audited, as per the plan. Working documents are then agreed with the audit team, including forms for documenting findings, procedures and checklists  to be used and standard record keeping required for documenting meetings.

The audit is then kicked off with an opening meeting to introduce the audit team, the plan, methods, communications links between parties, resources needed and anticipated schedule and anticipated closing meeting date. The site HSE and onsite emergency response measures are also detailed from the outset.

The audit is conducted to determine if the subject EMS meets the previously estabished criteria. Evidence is gathered  through interviews, document review and onsite observations.

Audit findings are then made by comparing the evidence with the EMS criteria. Nonconformaties are then set out in a clear, concise manner, supported by evidence. Findings should than be reviewed with the auditee's manager to assure that there is an acknowledgement of the factual nature of the findings.

A close out meeting follows including management and those responsible for the EMS functions audited. A summary of findings is presented  to verify the factual basis of these and to address any disagreements over contentious issues.

The audit report is then prepared  under the direction of the lead auditor as per the audit plan and signed and dated. A review of the process followed and the EMS conformance and whether it is being properly implemented is included and a conclusion on whether the internal management review process observed is able to implement the EMS provided.

The audit report is then distributed in keeping with the plan and all working documents and drafts retained by the auditor.

Corrective action requests and follow up investigations can then take place to assure EMS compliance. A review of the final findings with management can then follow, so that continuous improvement of the EMS is assured.

For further information on environmental auditing please contact: info@alexramsay.ca