Internal Audit

Environmental Services Audit Checklist

The environment in which we live is of crucial importance. We cannot take any kind of risks when it comes to the environment because it is where we live and breathe. Whenever in the past the environment has not been taken care of, we have seen the results of the same quite clearly. If we are not feeling well, why do we prefer to go to hill stations? Because the air quality is good and our senses feel relaxed when we go to such places.

The audits in this sector refer to the examination or investigation that has been undertaken by different organizations in order to ensure compliance with the policies that are in place for the environment. The assessment in this area is there to test the pollution level and the kinds of pollution which is caused. What is the level of danger, and is there any sort of actual harm that is caused? This auditing is also a tool which assists the organization or industry in verifying compliance with the auditing standards or assessing the risks and the environmental hazards. The pollution which is created by the industrial sector can be reduced with the timely conduct of environmental audits.

The Environmental Management System (EMS)

The environmental management system refers to all the policies, processes and practices used by the company so as to manage the environmental impact. There are some companies that take a step further and get themselves audited & also certify them to the International Standard of Auditing, which is ISO 140001:2015.

The globally recognized standard for environment management is ISO 14001. ISO: 14001 is a standard that can be used by organizations of any size and type. Organizations at any level of environmental performance can use this. It is a kind of practical framework that is used largely for reducing the risks in the environment and to further demonstrate the commitment towards sustainability goals. This standard provides for the development of an EMS that includes many steps.

This framework is used by organizations to manage the environmental impact they are having.

Requirements for EMS are-

1. There should be an environmental policy. The impacts and aspects of the factors which are affecting the environment.
2. The objectives of such environmental policy should be verified.
3. The operational control should be implemented, and the review of the system should be there.

Review of the EMS

There must be a review of the EMS system. The organizations should work on improving the EMS. It will involve the following points-

1. The conducting of regular audits.
2. To review the EMS and ensure that it remains effective and relevant.
3. To continuously work towards making improvements or required changes.

ISO 14001: 2015 Clauses

Clause 4.0- Context of the Organization

It involves an understanding of the organization and the context. To know the needs and expectations of the parties that are interested parties. To determine the scope of the EMS.

Clause 5.0- Leadership

This clause talks about leadership and commitment, the environmental policies and the roles and responsibilities of the organization.

Clause 6.0- Planning

• The planning clause consists of the actions for addressing the opportunities and the risks.
• The objectives of the environment and the plans for achieving them.

Clause 7.0- Support

This clause includes-

1. Resources
2. Competence
3. Awareness
4. Communication and
5. Documented Information

Clause 8.0- Operation

It includes the operational controls and planning. It further includes the response and emergency preparedness.

Clause 9.0- Evaluation of the Performance

It includes the monitoring, evaluation and measurement analysis. The evaluation compliance and management review.

Clause 10.0- Improvement

This clause is all about how improvement is the integral factor for being an effective Environmental Management System by the general non-conformity and corrective action and continuous improvement.

Improvements in the ISO 14001: 2015

ISO 14001:2015 new requirements include-

The environmental management should align with the strategic direction of the organization. A better commitment from the leadership. Some initiatives should be taken to protect the environment from degradation, for example, mitigation of the change in the climate and the use of sustainable resources. It further allows for easy integration into different management systems because of the similar terms, definitions and structure.

ISO 19011: 2018

This standard has guidelines for the auditing management systems that are the audit process, which will determine the scope for establishing the audit criteria by the collection of the evidence, evaluating the evidence, and then drawing a conclusion based on the findings.

EIA (Environment Impact Assessment)

The EIA checks whether the development of infrastructure in the nation is environment-friendly or not. In the Rio Summit relating to the environment, which was conducted in the year 1992, the EIA was accepted as a good practice for checking up on the impacts on the environment. In India, the EIA was introduced in the year 1978. The EIA was introduced before the Environmental Protection Act in the year 1986. In 1994, EIA was brought under the ambit of the Environment Protection Act. A lot of projects were cancelled in the past, and so there were debates regarding the fact that the environmental protection norms are not allowing for the development of the infrastructure in the nation. These mechanisms for checks were commonly used by the political parties in their speeches, stating that the environmental norms are an obstruction to the development of the industrial sectors or infrastructure. This ‘Green brigade’ started to be known as the ‘New Red’. 

Whether the nation is a developed or developing nation, the environmental audit is important. No matter how many industries are developing in the nation, this development should be sustainable. This impact assessment was introduced for the first time in the U.S. by the National Environmental Protection Act (NEPA) 1970. Under the new EIA notification of 2006, the projects have been divided into two categories:-

Category A

These are projects at the national level in which the EIA is mandatory, and the approval is given by the Environmental Impact Assessment Authority.

Category B

In this category of projects, the approval is given by the State Environmental Impact Assessment Authority, or the states can also ask to review the assessment, which has been done under Category A. Therefore, the Category B has been further divided into two categories:-

Sub-categories of Category B

Category B1– The EIA is mandatorily required for these types of projects.

Category B2– These are the projects which do not require EIA.

Exemptions

The projects which are totally exempted from the EIA requirement are-

1. Defence projects– The projects of the security sector of the country are exempted. Also, the projects falling within the radius of 100 km of LOC are exempted, too.
2. Power plants– The power plants of 15 megawatts and the power plants based on hazardous solid waste, where the auxiliary power of up to 15% is used.
3. The ports for fishing are exempted.
4. Toll plazas are exempted.
5. The expansion in the airport terminal building is exempted.

Basically, all the flagship projects of the government, for instance, infrastructure projects or connectivity projects, etc., are exempted.

The Checklist for Environmental Audit

Although there are plenty of checklists that are available online, they have their own approaches. The International Organization for Standardization issued a checklist for small businesses, which divides the process of auditing into different steps. The checklist shall include the following as mentioned below:-

S. No	Checklist
1.	The scope of the EMS or environmental management system
2.	Environmental Management
3.	The legal requirements and the environmental aspects
4.	Policies for the environment
5.	Training, Awareness and Competence
6.	Communication
7.	The targets, objectives and programs for the environment
8.	The roles, responsibilities, resources and authority
9.	Documentation
10.	The review of the management and constant improvement
11.	The operational controls
12.	Internal Auditing
13.	Response and emergency preparedness
14.	Review of the management
15.	Demonstrating the conformity
16.	Integration with other Management systems

Some additional items for the checklist are given below-

Review

At the time of reviewing the records, the focus should be on the documents which might expose the company to liabilities. Examples of the same include- emergency response plans, permits spill control plans etc.

Disposal Sites

At the time of inspection, the waste disposal sites have to be scrutinized very carefully. Hence, this item must be on the checklist. It is to be ensured that the practices should strictly follow the federal or state guidelines. The violations relating to waste disposal can, at times, be very costly. If cleanup efforts are required, then one must be required to pay if needed.

Vehicles Usage

The waste transport vehicles should be safe, and they must be well maintained. Inspections should be done regularly for the vehicles. The supervisors should make sure to at least do an inspection of the vehicles quarterly. And being the drivers of the vehicles, it is also the responsibility of the drivers to keep a check on the condition of their vehicles.

Incinerators

They actually create a lot of worksite hazards. If these are damaged, then the possibility becomes higher of the staff getting injured.

Tanks

The storage tanks are also crucial for including in the checklist both aboveground and underground tanks. They need to be checked for corrosion or leaks, etc. While doing the audit, these fittings and pipes should be checked too.

Buildings

The buildings which are used for storing hazardous materials or waste should be inspected properly. The containment buildings are also an important subject of scrutiny. All the key systems where there is a possibility of damage should be checked, including the windows, ventilation of the building and the roof, etc.

Security

If there are hazards at the site, then it must be secured. The security measures for such hazards must be updated. Examples of these include gates, fences, locks, etc.

The equipment for communication

During the leak or spill, the communication equipment is crucial. Hence, this equipment should be on the checklist. The emergency systems and the functions of these equipment.

Sample Report (In the Questionnaire form)

Environmental Policy
Is there a display on the website of the company about the environmental policy?	Yes/No
Whether the policy is signed by the CEO or not?	Yes/No
Are the environmental factors included in the risk assessment?	Yes/No
Were the emergency provisions addressed?	Yes/No
Are the sub-contractors complying with the environmental policy of the company?	Yes/No

Steps for Conducting an Environmental Audit

It can sometimes be difficult to create an environmental audit checklist. However, the below-mentioned process can help-

• To identify the scope of the audit– It is crucial to first determine the areas which need to be audited like the products of the organization or facilities of the organization, etc. It will help in defining the boundaries of the audit.
• Review of the environmental norms– One must be well aware of all the rules and regulations governing the environment to make sure that during the auditing process, all the areas are covered. The regulatory bodies for the environment should be consulted to know the relevant requirements.
• Developing the criteria for the Audit– It is always better if different criteria are there to review the different areas. It can include the minimum requirements which must be there.
• Checklist– The questions or statements can be included for creating an environmental audit checklist relating to different standards. This checklist should be easy so that the auditor can easily verify the areas where improvement is necessary.
• Responsibilities– It must be outlined who will conduct the audits, and the roles and responsibilities should be assigned accordingly. People with expertise in environmental laws, like internal auditors or external consultants, can be included.
• Conducting the Audit– The checklist for the environmental audit can be used to check and verify the improvement of the organization’s performance in the environmental norms, and the areas where the improvement is required can be marked. The personnel of the organization can be interacted with to complete the audit.
•  Developing the action plans– The results of the audit can be used for identifying the areas in which improvement is necessary. Recommendations can be obtained depending on the potential impact and feasibility. Hence, action plans can be developed to address the deficiencies.
• Corrective measures– The corrective actions that are identified in the previous steps can be used for implementing these corrective actions. The progress towards the environmental goals should be monitored regularly and tracked down.

Stages of EIA

The stage of scoping has been formulated as per the International Standards. Now, the public consultation need not be in physical mode alone. The public correspondence can also be used.

Enforcement of the Environmental Regulations

Compliance monitoring is a very critical component that the EPA uses to ensure that employers are obeying the laws and regulations concerning the environment. This monitoring encompasses the regulatory agency activities that are performed to determine if the facilities or group of facilities comply with the laws that are applicable. It further includes-

• The implementation of the compliance monitoring strategies and their formulation.
• The support and inspector training
• The compliance monitoring is onsite, like investigations, inspections or evaluations, which includes the permit review or other documentation.
• Inspections
• The compliance monitoring, which is offsite, like reporting, collection of the data, coordination of the program, etc

The time-to-time inspections are essential for the EPA’s compliance monitoring programs. They are very crucial tools to assess compliance with the regulations for the environment. The regulatory partners and EPA keep conducting compliance inspections under the majority of regulatory and statutory authorities. These inspections check whether the facility is complying with the state, federal or local laws. It includes the pre-inspection activities like obtaining the general site information before entering the facility. Other activities include-

1. Clicking photographs
2. Reviewing the reports and records
3. Collection of samples
4. Interviewing the facility
5. To observe the facility or site operations

The usual format of conducting these inspections is that they focus on a single area at a time, for instance, the CAA or Clean Air Act. But they can also be conducted for more than one media program. They can also be performed to address if specific problems pertaining to the environment exist in different industries or facilities. These CAA evaluations can be either a Partial Compliance Evaluation (PCE) or a Full Compliance Evaluation (FCE). FCE is kind of a comprehensive evaluation of the compliance status of the facility, and it looks for all the regulated pollutants.

Conclusion

As we have seen above, the environmental audit becomes one of the most crucial areas for conducting audits because it is about verifying the factors that are injurious to our health. Since the last two decades, there has been tremendous improvement in the auditing sector of the environment pertaining to the awareness which was missing earlier, but nowadays, with the advancement of the media, the population at large is clearly able to identify the need for auditing in this sector. However, the EIA norms need to be followed pretty clearly by the companies or organizations as compared to now.

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