EHS Compliance Audit Planning: Tips for Success
Drawing on her extensive experience in auditing sites across many different industries and jurisdictions, Enhesa’s Sarah Toussaint provides her key tips for making EHS compliance audits a success.
Question: What makes a successful compliance audit?
Answer: Meticulous planning.
The success of an EHS compliance audit is dependent on ensuring it is properly planned to have minimal disruption to production whilst ensuring the audit team can achieve the audit objectives. A poorly planned audit puts significant additional strain on all involved parties and may put the audit at risk of failure.
After defining the audit scope and facility to audit, there are some key planning points to consider to ensure audit success.
Having the Right EHS Audit Software
The success of an audit will largely depend on the basis used for it. In order to conduct an EHS compliance audit, the auditors must know the criteria (i.e. regulatory requirements) in the country and region that are active at the time of the audit. In many cases an auditor may have come from elsewhere in the company, even from another country, and may not be familiar with the local regulations.
By having the right EHS audit software with regularly updated content, any auditor with experience in participating or leading compliance audits and with a basic understanding of the regulatory environment in the country, can conduct an EHS compliance audit at a site in a particular country. To ensure success, be sure that the regulatory content provider, such as Enhesa, provides not only all the EHS regulatory requirements in the jurisdiction, but also detailed guidance on the requirements and links to the original legislation. In addition, the regulatory content should be provided in dual language, so the auditor can see both the requirements in English and in the local language of the facility. This greatly assists communication with the local site personnel ensuring that all the terms are correctly translated from/to the local language.
The success of an audit will largely depend on the competence of the audit team selected to perform it. An efficient audit team must be able and competent to cover all subjects of the audit and the lead auditor should have auditing experience in the industrial sector that the auditee belongs to. Using this experience and the audit management software, the auditors should be able to audit any facility in the industry sector, wherever it may be in the world.
The facility language is also an important consideration. The audit team must speak the local language(s) in order to communicate with site personnel and read the site documentation. Where this is not possible, interpreters must be provided.
Every successful audit needs an audit schedule or plan to facilitate coordination of audit activities. Once drafted the audit plan should be distributed to the site and those responsible for the corporate audit program, and adjusted both prior to the audit and during the audit itself to account for the availability of personnel and how the audit is progressing.
Time during the onsite portion of the audit is often limited. To maximise efficiency and avoid wasting time, topics and regulations that aren’t applicable to the site should be removed from the audit schedule prior to the audit. This can be done by having regulatory content, such as Enhesa’s, integrated in an EHS software like Enablon, which allows both the auditor and the auditee to easily determine the applicability of EHS regulatory requirements to the site to be audited by answering a set of simple questions about the site’s activities.
Another consideration for drafting a successful audit schedule is prioritising the assessment of new and changed regulations. Even sites with a very good overall EHS compliance may face problems when confronted with changed regulations. By allocating more time to the assessment of the site’s performance against new and changed regulations, the audit can better ensure identification of issues. One way to identify new and changed regulations is by using the “flag major changes” function in Enablon’s audit management module.
The audit should be preceded by a conference call or meeting between all parties. This will allow all the actors to meet each other, and should take place several weeks before the audit to allow the audit team and auditee to prepare and include the auditors and key EHS staff at the auditee’s facility. The call also has the key role of making sure the auditee is invested in the audit process. If the site does not want the audit to go ahead or is simply “too busy” to prepare for the audit, you can almost guarantee that the audit will not be successful.
The contents of the pre-audit meeting or call should include the audit objectives, the audit scope (the activities to be audited; whether the compliance audit includes EHS legal compliance only or whether it includes corporate standards; whether the compliance audit includes national requirements only, or whether it includes sub-national jurisdictions and mandatory standards; the audit period (i.e. how far will the audits go back in looking for records); exclusions from the audit scope – will abnormal operations such as maintenance and construction be included?), the site to be audited, audit logistics (how the auditors will get to the site; lodging; site access information; internet access for the auditors during the audit; medical restrictions; clearance to take photos; meeting room availability, etc.), discussion of the audit schedule, safety on site and communication channels.
Reviewing a large number of documents is an integral part of any audit process. To ensure that the documents are available during the audit, the auditors should send the site a list containing all the documentation that the audit team expects to review prior to or during the audit. The right EHS audit software can save time for auditors by providing a pre-made list of documents. This is particularly useful for companies operating in many jurisdictions where the regulatory requirements and therefore the documents required to support them differ from place to place.
The pre-audit document list should be provided to the auditee as early as possible to allow them to prepare. Although many documents may exist on the site’s intranet or other IT systems nowadays, the site will still need to arrange for a knowledgeable person to explain the system and show examples to the auditors.
Planning EHS compliance audits takes time and the collaboration of the auditors, corporate management and the sites to be audited is essential to the success of the audit. The time spent planning the audit and onsite can be minimized and the results maximised by using intelligent audit management software that can not only provide all the regulatory requirements and guidance for a particular country and jurisdiction, but also has functionality to screen out requirements which are irrelevant to the site, highlight any new or changed regulations and assist the auditors and the site in preparing the audit.
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