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
10/30/2015 For the MECC – Chicago 3
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
10/30/2015 For the MECC – Chicago 4
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
10/30/2015 For the MECC – Chicago 5
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
10/30/2015 For the MECC – Chicago 6
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
10/30/2015 For the MECC – Chicago 7
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
10/30/2015 For the MECC – Chicago 8
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
10/30/2015 For the MECC – Chicago 9
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)
10/30/2015 For the MECC – Chicago 10
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
10/30/2015 For the MECC – Chicago 11
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
10/30/2015 For the MECC – Chicago 12
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
9/15/2015 For the Baltimore AR Fall National Meeting 13
