nick steinke, tellevate, 10 tips for implementing an effective audit program, midwest environmental...

Midwest Environmental Compliance Conference

Chicago, IL – October 30, 2015

10 Tips for Implementing an Effective Audit Program

Principal, Manager of

Tellevate’s Compliance

Services

– Certified environmental and management systems auditor

– Previous experience as a Regulatory Environmental Engineer

– B.S. Manufacturing Engineering, Boston University

Areas of expertise:

• Environmental compliance program support

• Air quality compliance

• Multi-media compliance auditing

• Management systems

• Agency consultation and litigation support

10/30/2015 For the MECC – Chicago 2

Nick Steinke, P.E., CPEA, SFP

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1. Obtain Management Support for Established Project Objectives

Implementing an Effective Audit Program

• Management Support is Key

• Use Management Priorities to Establish Program Objectives

• Program Objective Considerations

• Compliance

• Continual Improvement

• Technical Assistance and Training

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2. Define the Audit Scope and Protocol

Implementing an Effective Audit Program

• Regulatory Scope

• Permits, Plans

• EMS?

• Protocol

• Content: Questions? Checklists? Lists?

• Citations/References

• Updates

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3. Include Root Cause Analysis and Other Key Metrics

Implementing an Effective Audit Program

• Root Cause Analysis

• Map to EMS -> Business Processes

• Prioritize Findings

• Emergency | Regulatory | Policy | BMP

• Environmental Media Area

• Location (Facility? Building? Room?)

• Responsible Organization/Program Area

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4. Consider Technical Assistance and Training

Implementing an Effective Audit Program

• Plant Participation and Buy-In

• Corrective and Preventive Action Timeframe

• Cost-Effective

• Promotes Open Communication

• Supports Root Cause Analysis

• Overall Program Success

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5. Leverage Technology

Implementing an Effective Audit Program

• Data Collection

• Reporting

• Analysis

• Framework for Consistency

• Protocol Integration, Updates, Customization

• Communication

• Within the Organization

• With Management

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6. Establish Formal Reporting Process and Timeframe

Implementing an Effective Audit Program

• Report Content

• Clear

• Concise

• Objective

• Clearly Distinguish Findings and Recommendations

• Timeframe, Corrective Action and Liability

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7. Establish Formal Corrective Action Process

Implementing an Effective Audit Program

• Audit Findings -> Report -> Now What?

• Timeframe

• Liability of Long/Undefined Internal Process

• Roles and Responsibilities

• Corrective and Preventive Action (Address the Root Cause)

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8. Use Qualified Auditors

Implementing an Effective Audit Program

• Credibility

• Audit Quality

• Technical Assistance

• External Auditors

• Benchmarking

• Overcome Institutional Norms, Constraints

• Stakeholder Perception

• Community and Regulator Perception

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9. Use Risk-Based Approach

Implementing an Effective Audit Program

• Resource Considerations v. Considerable Audit Protocol

• Focus Auditor Resources on Issues with Greatest Risk

• Environmental Impact and Regulatory Liability – What Else?

• EMS Alignment Keeps Process Consistent with Organization Goals

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10. Document Formal Audit Program

Implementing an Effective Audit Program

• Clearly Define and Communicate Program Objectives and Approach

• Establish Accountability

• Define Roles and Responsibilities

• Audit Program Manual/Procedures

QUESTIONS? Nick Steinke

402.730.1660

nsteinke@tellevate.com

9/15/2015 For the Baltimore AR Fall National Meeting 13