ENVIRONMENT.. AUDITS; THEORY AND PRACTICE

Steve Cook, Marketing Manager, Cremer and Warner

Introductton community and regulators, reduction in costs, increased information transfer, improvement in environmental awarenesg

Over the pnst twelve months, there has been a tremendous growth improvement in yield and quality. Disbenefits include: in the demand for environmental audits from all sectors of commitment of resources to run the programme, mnfidentiality industry ad, not surprisingly, the most significant growth has of f inhgS, increased liability if 110 response is taken, temporary been in those industries which are perceived to offer the greatest dmPtion of Plant operations. threat to the environment.

The disbenefits of auditing mean that it is vital that the Environmental auditing or “Green auditing“ as it is now management understand that if an auditing programme is cMllIIlonly refened to is booming. Needless to say, there me an implemented any Problems identified must be solved, otherwise ieCreaSing n m h r of less reputable consultants in the business the audit report could be h-hg in a court case or insurance and little has been done to formalise and regulate the standard of Claim, however, as m V e m a t ignorance is no defence, many auditing in the UK. However, there are a nmber of reput&le Companies have opted to Carry out an auditing programme as it is companies offering environmental auditing services, often to a better to know the liabilities than to be totally unaware of them. formal procedure unique to thcse companies and in general tenus it is fair to say that the standard of audits curreptly undertaken is Qualities for an Auditor fairly high.

Before actually examining the audit procedure, it may be worth This article aims to provide an b i g h t into the theory of the audit considering what the would-be auditee should be looking for when process, what the audit should address, and the type of problems selecting candidates to undertake the auditing programme. There encountered in the real world. are a numbex of criteria which may be seen to be important and

certainly some of the criteria may be dictated by the reason that Theory the audit is being done. If we m e , for the purpose of this

study, that the study is being commissioned in order to firstly examine the company environmental performance, and secondly

What is an Environmental Audit? to identify deficiencies, lack of compliance with legislation and exposure to risk of environmental impairment then the following

Although environmental auditing is very much a growth market, applies: it is surprising how many people, including our clients, who are not aware of what the audit is and what it entails. Independence - total independence from any authority body,

m a j a organisation, or common industrial group should always be There are a number of definitions which have been proposed by sought. lhis will avoid any unpleasant conflicts which may arise ~ a r h ~ SwceS, for instance: ”An h & P d e d , Systematic, in the event of either immediate problems which are identified periodic, documented and objective evaluation Of how Well during the initial audit, Or co&ntatim &g from incidents environmental O r g d i o n S , management and e@Pent me which occur shortly after the audit has been completed. perfomkg with the aim of helping the company management to safepard the envirWment by facilitating management and control C l e d y Defined Strategy - from the definition quoted earlier in of environmental practices and compliance with this article it is obvious that the auditing procedure must be a company policies which include meeting regulatory re¶UiremdS.” fmJdkd logical and systematic process. Most reputable

consultants will be able to produce a basic framework for In reality the audit is simply a verification programme. The audit approach which will be adopted for all audits regardless of their shwld verifsr the existence a d use Of adequate Systems objective. ObviouSly these basic frameworks will have to be competently applied. modiied to suit the requirements, not only of the objectives set

but also for the individual plants on which the audit is being Why Audit? undertaken.

Many audit pogrammes (LIC &signed to meet specific Objectives, Demonstrative Awareness of kgklatbn - a clearly for M m c e definition of insurance liabilities, pre-acquisitiw. d e m ~ ~ ~ ~ ~ ~ a t e d awareness md f d i d t y with both cment and audits, waste audits, compliance audits, warehouse audits, process anticiFed future legislation should be shorn bY the consultants safety audits, pgswnel safety audits or product safety procedure^ auditins programme- Again referrins back to the audits. definitions the audit is a process of verification. An important part

of the auditing programme is obviously to identify that site In the c~se of the environmental audit, a number of benefits may operatioas meet h h regulatory and ~ V ~ ~ e n ~ b moral be assumed for commissioning this type of work. However; there re¶Uirments. wi l l also be a number of disbenefits which it is important to appreciate before undertaking an auditing programme. Understanding of Objectives - I am referring here mainly to the

tailoring of the basic strategic framework for the auditing Benefits include: Assurance of compliance, reduction in surprises, programme. Different audits will be undertaken to satisfy the prevention of fmes and suites, improved public image with the variety of objectives, and if we look back at the reawns for

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auditing, it is fairly obvious that the objectives specified for each of these reasons are somewhat diverse. If for example the audit is commissioned in order to support an application for pollution insurance or environmental impairment liability (EL) cover then the audit should concentrate on those areas which may present a risk of accidentally polluting the site and surrounding environment. All possible routes for pollution by land, air and water should also be addressed together with noise levels generated as a result of non-site operations. Legislative compliance should also be addresed as any non-compliance may render the policy invalid.

Specialist Expertise (Air, Water, Land, Noise) - Although the audit will normally be undertaken by one or possibly two scientists it is important that the consulting company can demonstrate specialist expertise in all four forms of pollution. This ensures that firstly. the auditors can be selected to suit the anticipated problems on the site being audited, and secondly, should a serious problem be identified during the course of the audit this CM be addresed by the same company in an efficient and hopefully competent manner.

Independent Analytkal Capability - this does not necessarily have to be part of the consulting organisation, although it is certainly of benefit, but a mutually acceptable source of independent analytical capability should be identified prior to the start of the audit programme, in order that any analysis during or as a result of the audit can be completed under a pre-defied and agreed format.

Audit Methodology

As I have already pointed out there are no formally approved guidelines for the auditing process, and the methodology that is proposed here is one that is adopted by Cremer and Warner in our auditing programme. It is important to realise that at most sites the day-tday operations fully tax on-site staff resources and therefore, the audit must result in as little disruption as p i b l e . The audit procedure may be split into three main categories, pre audit, on-site audit and post audit.

F’re-audit activities will involve the despatch of a pre-survey questionnaire (PSQ) submitted to the subject facility to enable the audit team to familiarise themselves with the type of environment related activities on the site prior to the visit, and also to focus the minds of the management and staff on what will be required of them and information that should be made available during the audit. A review should be made of relevant regulations and these will normally be dictated by the geographical location of the site and/or the material inventory. The audit team should normally be allocated such that disciplines within the team are relevant to the site being audited. A detailed agenda for both the audit teams and on-site personnel should be prepared BS this will result in the most effective use of time s p t on the site.

The on-site audit may be broken down into the following parts: - A record documentation review conducted on f d

arriving on the site will provide the auditor with an appreciation of key compliance issues at the facility. Product data sheets, discharge consents, waste licences, etc. should all be scrutinised before the physical audit.

- Further information will be gained by interviewing facility staff and this is possibly the single most important aspect for the audit, the four golden rules are: Firstly to schedule

interviews ahead of time. interrupting a busy staff member will not be productive. Secondly to interview in the workplace, as this may result in relaxed conversation, access to records is often easier, and most importantly, the interviewer can witness first hand the facility under discussion. Thirdly, observe interviewees body language, auditors are generally seen as a threat. If an interviewee becomes obstructive or sarcastic it is better to terminate the discussion. It is important for the auditor to try to put the interviewee at ease. Finally, avoid yeqno responses as little can be gained in terms of infomation. Attempts should be made to establish free flowing information exchange on a conversational basis.

- Physical inspection. It is not possible to describe the physical inspection in detail as this is very much dictated by the site in question, however there are a number of general points which should be observed: 1. Inspect remote areas. 2. Time observations to verify compliance. 3. Check safety features - don’t asume they operate. 4. Make boundary - nuisances are often easier identified from outside rather than inside the facility. 5 . Check sampling procedures - the results are only as good as the analytical techniques used.

- Out brief. The out-brief or de-brief allows for an informal discussion on the audit findings and avoids misinterpretations being formalised in the final report. It a h provides the audit team with an opportunity to collect additional information required as a result of the earlier tasks.

Post Audit

A formal report should highlight all findings and deficiencies of the facility. Recommendations should be prioritised in order that the more crucial issues may be tackled first.

Practice

In order to demonstrate the actual auditing procedure, I have used a hypothetical case-study which obviously incorporates some real-life experiences from audits which have been undertaken for a variety of reasons, and for some very different clients.

Background

The site operates as an Aluminium castings facility and is based in a heavily populakd area in the UK, with an estimated 2000 people resident within half a mile of the site and several hundred thousand people within one mile.

The site has been involved in casting of metals since 1800 and the area may be considered as a particularly old and industrial one and therefore it will be difficult to predict what historic contamination is present in the ground.

The plant houses two main induction heated melting furnaces which each have a 9 tome capacity. Some 90% of the alloy brought onto the site is in the form of ingots with the remainder being in the form of items collected from scrap merchants. .Flux is added to the furnaces which melts and floats on top of the molten metal and this flux liberates chlorides, chlorine, fluoride and fluorine when decomposed. Its purpose is to prevent oxidation

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and to scavenge metal oxides. Molten metal is tapped from the furnaces into a mobile crucible and a further quantity of flux sprinkled on it to protect it while it is being transported to the casting area

There are a number of storage tanks around the site containing diesel oil and hydraulic fluid, and a waste oil storage facility into which oily mixtures from ground sumps are pumped on a regular basis. A number of 200 litre drums with a variety of contents are stored at various locations around the site.

The foregoing together with additional information received by way of a pre-survey questionnaire indicates that there may be problems associated with air emissions and possibly waste disposal. The selection of a suitable auditor is based on this information. A fm appointment is made to attend on site via the Site Manager and the Health and Safety Officer.

The Audit:

An auditor who has specific experience in air emissions, is selected for the audit and he is accompnied.by a junior scientist with experience in waste management. They arrive at the site at 09:OO and meet with the Health and Safety Officer who has only been on the site for two weeks, and are told that the Plant Manager is unavailable. As a result, the in-briefing is somewhat foreshortened and when the record review is requested Little documentation is made available. It appears from the scant information that is available that there is one discbarge of trade effluent to foul sewer. This is from the shop in which castings are agitated with lumps of hard ceramics used to polish metal surfaces. A considerable volume of water containing alkali wetting agent flows through this plant and so metal fragments and abraded ceramics are washed out.

The flow of effluent is taken to a settling tank where the largest solid particles are deposited, the overflow is then discharged to foul sewer. It is assumed that a formal consent to enter the sewer with conditions set out on maximum volume and effluent cornparition exists. There is a meter on the discharge and the water authority charge for its reception. No consent was available for scrutiny on attendance at the site. No information is made available on where storm water goes from the site other than to foul sewer. There is a compressor house on site, however, no noise readings either on or off the site have been taken.

The waste contractor used by the site operators are not members of the National Ascciation of Waste Disposal Contactors and it appears that the contractor was chosen because they were cheaper than a larger more reputable contractor.

All the waste is disposed of in common vessels and it is unclear whether some of the material being disposed of does not fall within the Control of Pollution (Special Waste) Regulations, 1980. No consideration seems to have been given to this possibility. The site is also accepting scrap aluminium which is being processed and converted into re-usable material. This could in theory mean that the site is operating as a waste treatment plant which should be subject to a licence under section 5 of the Control of Pollution ACT 1974, and the Collection and Disposal of Waste Regulations 1988, SI 1988 No.819.

The record system on this particular site is non existent and no systematic sampling of emission tp atmosphere, sewer or streams

has been undertaken.

Having cited mast of the records which exist, scant as they are, the physical audit gets under way at approximately 10:30.

The methodology adopted for this particular site, as in a number of instances, is to follow the manufacturing process from raw materials through the process and to fmal product taking note of any discharges along the way and wastes generated as a result of the process.

The raw stock for this aluminium dye casting works, being mainly in the form of metal ingots is stored in large skips and mixed with scrap aluminium prior to introduction to the furnace. Other materials stored on-site are as follows:

- There is a diesel oil tank on the site, the diesel is used for transport vehicles and as furnace fuel. The tank is old and is supported on steel girders, its lower end being about 1.5 metres above ground level. Adjacent to this tank is a similar but smaller tank containing hydraulic fluid for use in the piston mechanism of the casting machines. This is understood to be a water miscible composition based on glycol. Neither of the tanks are bunded and any leakage from them would soak into the soil beneath. They are filled by bulk delivery. The ground around these tanks appears badly contaminated due to spillage.

- There are a number of open ground sumps in the casting locations and there are also further open ground sumps which appear to have no current purpase but were installed in the past and although generally redundant do collect floor spillage. One such sump against the back wall of the foundry is only one metre away from the retail-DIY warehouse at the back of the site. The oily mixtures from these various ground sumps is pumped directly to two large cylindrical storage tanks situated behind the foundry.

- On investigating behind the foundry a disused area is found in which there are nine fuU 200 litre drums, which, according to the labels, contain lubricating oil. The drums have undoubtedly been stored in this location for some considerable time and appear in a particularly bad condition.These drums are sitting very near to a storm drain which would collect any leakage which occurs.

Turning now to the production side, the two furnaces on site are operated alternately and there is a single hood attached to a swivel device above; the belief being that it is only when fresh flux is being added that any emission of fumes occurs.

In general terms there are fluoride emission problems associated with the primary aluminium industry. As the flux used at this particular site is standard for the hdustry there may well be a serious fluoride emission problem.

The fume collection hoods in this particular case are in a poor condition. There is no fan associated with this ventilator nor is there any scrubber or other treatment to the emissions which pass out via the trucking. The use of de-gassing tablets and fluxes meam that there will emissions of both fluoride and possibly tetrachloroethylene. As the capacity of these furnaces exceeds 5 tonnes, the site will come under the provisions for Integrated Pollution Control in part 1 of the Environmental Protection Bill.

The main waste material disposal from the site is the oily mixture of materials which runs off the casting machina and ends up in storage tanks already described The material is removed two or three times per week in road tankers by a local process oil operative who could not be identified as a member of the National

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Association of Waste Disposal Contractors during the document review. The company were informed that unless they obtain evidence that their waste is being disposed of in a correct and legal manner they may be liable to prosecution under the ”Duty of Care” regulations. Although the largest component of the oily waste disposed of is water, there are many other materials admixed which are largely undefined but which may well result in the composition falling within the Control of Pollution (Special Waste) Regulation, 1980. No consideration seems to have been given to this possibility by those on site.

A number of combustible wastes are bunt on-site in what may be described as an incinerator, but which is little more than a steel box, with a piece of cormgated iron beside it. The incinerator is directly adjacent to the diesel oil storage tank.

A general wander around the site revealed that there may be a major asbestos problem in several locations. Many of the buildings are in a dilapidated state and in some areas ceiling panels which may contain asbestos are hanging off, and in other c e s are broken and parts missing. One particularly bad area is a large warehouse which is more or less derelict. Immediately outside this building is the yard of the primary school where children play while waiting for parents. Complaints have been received from residents that pi& of the old school building roof, including sheets of glass have fallen into the school yard where children play. An immediate investigation is recommended in order to ascertain the full extent of the asbestos problems.

A number of large transformers are discovered on the site which may contain PCB’s. No information is available from either site personnel or by way of plates fixed to the external casing of the transformers.

At the end of the physical audit an attempt is ma& to meet the Site Manager for an outgoing brief, however, once more our sweyors are told that the Site Manager is unavailable. The Health and Safety Officer informs our sweyors that it is unlikely that if they return, he will still be employed on the site.

Reporting

The formal repon obviously includes a number of recommendations and these are placed in a system of priorities such that the most important of the issues may be addressed immediately. The priorities are based on a combination of the probability of significant impairment of the environment, whether past or future, and the coosequences that stem from it.

Priority one: indicates a strong probability of an incident or source of contamination which has substantial consequences. Urgent and effective action needs to be taken without delay.

1. A survey should be carried out by experienced contractors 10

determine how much of the detained materials in and external to the various buildings on the site contains asbestos. An initial estimate cost is provided at circa f2OOO. The burning of combustible waste in the ”incinerator” adjacent to the diesel oil tanks should cease immediately.

2. Contact should be made with the local water authority to establish a clearly written consent for discharge of effluent to sewer. A more detailed study should be undertaken on the whole issue of land drainage in the area. Periodic analysis on the effluent discharge from the plant should be carried out to establish that it is within specification. Estimated costs for this work circa f1500.

The list of priority two issues is as follows:

1. The condition of all ground sumps on the site should be examined to determine if they are still in use and if so, that they are in good condition. Initial inspections are estimated to cmt f looo.

2. Soil analyses should be conducted in locations where ground contamination may have resulted from spillage or leaking sumps. This is of particular importance in areas adjacent to the periphery of the site. Estimated costs for this study f5000.

3. All bulk storage tanks on the site including those containing diesel oil, hydraulic fluid and liquid waste from the casting shops should be examined. High quality secure b u d s for these tanks should be provided so that any leakages or spills when filling or emptying are not allowed to soak into the ground. Initial estimated costs f4500

4. The local HMIP office should be contacted to enquire if the site should be registered as operating a prescribed process.

5. The atmosphere in the vicinity of the melting furnaces should be examined to determine how much fluoride anaor ciher substances are being discharged from them. The ventilation system from these plants should be examined to establish the efficiency with which the materials discharged are removed to the external stacks provided. The determination of occupational exposure to fluoride is likely to cost around f 1500, hut will be dependent on the frequency required.

6. The nine redundant drums of what appears to be lubricating oil at the rear of the foundry should be removed and disposed of by a reputable waste contractor. An overall survey to locate and deal with any other redundant materials on the site should be carried out. Estimated mst for this exercise circa f 1ooO. Analysis of oily mixed waste generated by the casting machines should be carried out to determine whether this may sometimes fall within the definition of special waste analyses costs would be around €500.

wority indicates that there is a remote of An investigation should be carried out to determine whether the en-nment impairment that its is restricted waste contractors used by this particular site are in fact licensed, and hence urgency is reduced. Normal capital spending procedures and what the ultimate destination for the waste k* will normally be appropriate.

7. An investigation should be conducted to established which priority three: is given to items of electrical equipment on the site contain PCB’s. in the establishment of effective risk management. but which s e not dk&ly related to the immediate or &fmt,le 8. A noise survey at relevant locations should be carried out to environmental impairment. ensure that legal requirements under the Noise at Work

Regulations 1989, are being complied with. Estimated cost for this The list of priority one issues for this site is as follows: exercise circa f 1500.

are mdent steps to

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The list of Priority Three issues is as follows:

Paper submlssions from interested parties are invited for this keynote conference taking place in the Autumn of this year. Consultants, Academics. Students and Practitioners in environmental fields will be specifically interested tn this conference which focuses on the environmental development of Europe in the nineties. I t is hoped that a degree of consideration will be given to the imminent implications of establishing the Single European Market. Emphasis too, will be placed on papers which examine opportunities for 1 environmental development and restructuring

1. It was generally felt that a review of site security should be undertaken, particularly to prevent children gaining acces to the derelict buildings and waste skips.

2. Portable monitoring equipment should be purchased to compile statistics on air borne dust and fumes within the buildings. This is likely to c a t within the region of €1000.

Of all these problems identified at the different sites which make up this case all the priority one issues were addressed immediately. In the case of the derelict building, which did in fact exist on one particular site we visited, this was enveloped by placing plastic sheeting over the whole structure and demolished by specialist asbestos contractors following our own team of laboratory technicians having taken background readings of the level of contamination in the area. The demolition and removal of ruble from the building demolition was overseen by our own consultants involved in the original survey.

In the case of the incinerator which was being used directly adjacent to diesel oil storage tanks a follow up visit to the site two or three weeks after the initial survey showed that this practice had in fact ceased and that waste was being removed from the site by skip and that incineration of combustibles had been terminated.

And the final priority one recommendation following this hypothetical survey. This was in fact again a real life k u e and the site concerned after approaching the local water authority were granted a consent and consequently avoided prosecution under the Water Act 1989.

Although in this particular case the site and the audit are a combination of experiences, it would not be unusual to encounter these type of problems both in the UK and overseas. The attitude of those on site may often be obstructive, as was the case with the Site Manager on this particular site. There is no doubt that had he been more helpful then we could have worked closer with his team of people in order to tackle the problems, and possibly suggest directly how a number of the more minor issues could be overcome in the long term. As it turned out the site manger had no copy of the report, this being commissioned by the Group and undoubtedly his reputation within the corporation would suffer as a result.

In the case of large multi-national companies, which this example is supposed to represent, it is important for the Group representative to inform all sites of the purpose of the audit. Many site operatos will immediately see the audit as a policing exercise and will therefore be that much more hesitant in providing information freely. This is obviously detrimental to achieving the specific objectives of the audit, that is to verify whaf systems exist and how any deficiencies may be rectified

EUROPEAN ENVIRONMENT CONFERENCE - 1991 -

The University of Nottingham September 23rd-24thI 1 991

in Eastern Europe. Papers will be delivered in a period not exceeding thlrty-five minutes. with allowance given for a ten minute question period after presentation. Accepted papers should be submltted to the conference organisers for possible subsequent publication, and should not exceed 3,000 words when in this form.

The conference fee has not yet been flnallsed, but it is unlikely to exceed S115:OO for both days includhg food and accommodation, and copies of all papers delivered.

Interested parties are requested to submit a paper title and abstract to: ‘The Conference Organiser”, European Environment Conference, European Research Conferences, P.O.Box 75, Shipley, West Yorkshire, BD 17 6EZ. Tel: 0274 594402 [+44 274 594402 ex-UK].

For further details and a registration form, please use the same address.

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