Does your organization run internal audits regularly? Prepare for a regulator to come knocking at your door by catching areas of non-compliance before the inspector can. Internal audits allow you to identify gaps in your existing EHS programs and improve processes before an official inspection, so you can be confident in your audit-readiness.
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Internal Audits and Other Tactics to Improve Your EHS Program
1. Internal Audits and Other Tactics
to Improve Your EHS Program
Grace Rosario, EHS Consultant
Triumvirate Environmental
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6. Agenda
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Purpose of Internal Audits
Preparations and Audit Readiness
Audit Do’s and Dont’s
Debriefs, Close Out and Takeaways
Q&A
7. Purpose
• Corporate, internal audits are a form of quality assurance in
many industries
• Inspection of current processes and management systems to
evaluate gaps without a regulatory burden
• Proactive effort to get ahead of any regulatory audits
• Confidence in your EHS program’s audit readiness at all times
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8. Internal vs. External Audits
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Internal Audit External Audit
• A self-driven evaluation
• A “dress rehearsal” to test preparedness for
external audits and inspections
• Performance and results DO matter:
− A reflection of the site’s (and
individual) performance in the eyes of
the company’s senior leadership
o Need to instill confidence that
compliance and key risks are well
managed
− Results may be used to benchmark
against other locations
• Initiated and performed by a third party
(regulatory agencies, certification registrars,
and insurance companies)
• The “real thing” (not a dress rehearsal)
• Performance (good and poor) may result in:
− Issuance or renewal of permit, license,
certification, or registration
− Citation, fine, or penalty issued by the
third-party organization or relevant
interested party
− Impacts to business continuity
(shutdown of facilitiy or loss of
license/permit) or impacts to company
reputation
9. Agenda
9
Purpose of Internal Audits
Preparations and Audit Readiness
Audit Do’s and Dont’s
Debriefs, Close Out and Takeaways
Q&A
10. Audit Readiness
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• Invest in document management!
▪ The best programs can come under
scrutiny without strong document
management practices
▪ Document and file retention guidelines,
consistency in formats, assigning SOPs
with a numbering system
• Maintain a compliance calendar
• Organization
• Defined system and task owners
11. Audit Scope
• Understand audit scope and areas of
focus
▪ Often will focus on recently released
procedures or updated processes
• Ask for scope if one is not provided!
• Prepare and organize supporting
information around the scope
• Ensure programs, procedures, and
personnel involved in the audit scope
areas are in good working order
• Are we doing what we say we are doing?
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12. Get the Word Out
• With scope in hand, we can
identify stakeholders who will
need to be involved in the audit
• Don’t venture alone – gather
support from team members,
facilities staff, key personnel
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13. Review Past Audits
• Familiarize yourself with previous audit findings
▪ Avoid repeat findings!
• Run through findings and assess controls currently in place
• Use past audits as a gap analysis for upcoming audit
• Include stakeholders and key personnel in previous audit
findings – all involved should have good understanding of
progress being made, where you were, and improvements
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14. Audit Logistics
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• Agenda and schedule: Review schedule and make
sure it works for you and the people involved.
Assigning escorts and considering who will
accompany auditors is important!
• Determine who needs to be at opening, closing,
and debrief meetings.
• Book appropriate spaces for the audit and consider
location of auditors’ work space and other
accommodations.
• Be neat and orderly in planning and clear with
auditors on the time, place, and people they will be
meeting. The more organized you look, the better
your program will look!
16. Agenda
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Purpose of Internal Audits
Preparations and Audit Readiness
Audit Do’s and Dont’s
Debriefs, Close Out and Takeaways
Q&A
17. The Audit – Do’s
• Take copious notes
• Ask lots of questions to ensure you are clear
on what the auditors are seeing/finding
• Make a copy or keep account of any
documentation provided to auditors
• If the auditor takes a picture – so should you
• Avoid hazardous areas such as confined spaces
• Take the most direct route possible
• Take actions to mitigate risks were possible
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18. During the Audit – Don’ts
• Don’t offer opinions or additional information in
excess to inspector’s question
• Don’t be his or her “buddy”
• Don’t be overly confrontational or show frustration
• Don’t be afraid to say “I don’t know”
• Don’t be afraid to ask for clarification if you don’t
understand or agree with something
• Don’t speculate or assume
• Don’t be evasive. Be direct, succinct, clear in
responses
• Don’t lie!
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19. Agenda
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Purpose of Internal Audits
Preparations and Audit Readiness
Audit Do’s and Dont’s
Debriefs, Close Out and Takeaways
Q&A
20. Debriefs and Close Out
• Each day should have a debrief. Inspectors may:
▪ Request documentation or supporting information
▪ Provide preliminary observations
▪ Ask questions regarding site operations
• Your chance to clarify and question
• Assign owners and take action immediately to close
any gaps if possible
• Closing Meeting may provide draft of findings –
NOT the final report
• Take notes and share them with the team for a master
document. Avoid being surprised when
final report is distributed
• Team communication
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22. Post-Audit
• Address any immediately dangerous situations
• Have an idea of where the findings will be and establish action
plans
• Eliminate immediate risks and determine root causes for long
term solutions
• Prioritize time – when audit report is distributed, have the
resources to effectively address and implement changes
• Keep moving on with your day-to-day! Don’t let the audit
findings consume you
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23. Audit Report and Response
• The audit report should not be a surprise to you
• Celebrate the positive observations
• Provided a chance to review and respond to a draft
version – use this time to ensure all statements are
accurate and align with notes you have from audit.
• Ask for clarification where necessary
• Set action items, owners, and reasonable timelines
for completion
• Create recurring meetings to continue monitoring
action items
• Implement long-term solutions
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24. Takeaways
• Gain a different perspective on your programs
• Identify positive observations and improvement
opportunities
▪ Chance to shine, show off your hard work
• Document management and organizational
tools will continue to strengthen your program
• Preparedness is not a one-time value –
programs will be in place if and when an
external auditor comes knocking
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25. Agenda
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Purpose of Internal Audits
Preparations and Audit Readiness
Audit Do’s and Dont’s
Debriefs, Close Out and Takeaways
Q&A