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INDEX

Contents

1. INTRODUCTION 22. PURPOSE OF THIS DOCUMENT 6

3. WHAT IS ENVIRONMENTAL AUDITING 7

4. DIFFERING TYPES OF ENVIRONMENTAL AUDITS 8

Environmental Management AuditsEnvironmental Compliance AuditsEnvironmental Assessment AuditWaste AuditsEnvironmental Due Diligence AuditsSupplier Audits

5. THE DEVELOPMENT OF ENVIRONMENTAL AUDITING 9

Development of Safety, Health, Environment, and Quality AuditingEmergence of Sustainability Auditing and Corporate Social ResponsibilityEnvironmental Auditing ProgrammesRoles, Responsibilities and Activities within Environmental AuditingProcess involved in undertaking an Environmental AuditEnvironmental Audit Reports

6. SOME OF THE TOOLS AND TECHNIQUES USED IN AUDITING 25

ChecklistsQuestionnaires (Audit Protocols)QuestioningObservation

PhotographsDrill Down SamplingResearch

7. THE PRACTICALITIES OF ENVIRONMENTAL AUDITING 28

Psychology of auditingPolicing versus Continuous ImprovementA Snapshot in TimeQuality Control

8. ENVIRONMENTAL AUDITING AND DECISION-MAKING 32

TransparencyAudit report distribution

ConfidentialityParticipation of Stakeholders on AuditsAudit Follow-upAuditing and Formal Systems

9 CASE STUDY 33

10. CONCLUSIONS 43

11. REFERENCES 44

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INTRODUCTION TO ENVIRONMENTAL AUDTING

"Environment is surrounding atmosphere/ condition for existence" -

"Environment is an essential natural process or an outcome of

occurrence" "Environment is of two types, one is negative and the

other is positive":

Environment is generator: creation of life form is because of environment. Sun/moon,

sea/ earth, hot/ cold and forests/ desert etc; they together made an environment that is fit

for our existence. There are two different environments one is positive and the other one

is negative, life forms in both namely, pests, insects and others are cold blooded have

different conditions which suits them to survive that may not be suitable to us, both have

own identities. Most important factor is that negative positive factors have to join

together to form an environment for example mother/ father for birth of a child, negative/

positive of energy forelectricity. In the system of environment, both have integral role to

play. Where negative dominates outlines its systems and where positive dominates forms

its own.

Environment motivates to react: We are miserable when are in desert and

delighted when we are in lush garden. In a hospital we are in different mood and in disco

different. Environment motivates us to change our mood and reaction is in accordance.

We also generate/alter environment in our surroundings by our

practice: Depends on the behavior of the individuals. Positive thinkers have positive

feelings and negative thinkers it is negative, creates environment accordingly. This

process turns to evolutionary system when a group of people have same thinking that

initiates others to follow. Human lust and excessive usage of natural wood causing

deforestation, pollution heating temperature is negative environment for us.

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Environmental management system (EMS)

Refers to the management of an organizations environmental programs in a

comprehensive, systematic, planned and documented manner. It includes the

organizational structure, planning and resources for developing, implementing and

maintaining policy for environmental protection.

An Environmental Management System (EMS):

Serves as a tool to improve environmental performance

Provides a systematic way of managing an organizations environmental affairs

Is the aspect of the organizations overall management structure that addresses

immediate and long-term impacts of its products, services and processes on the

environment

Gives order and consistency for organizations to address environmental concerns

through the allocation of resources, assignment of responsibility and ongoing

evaluation of practices, procedures and processes

Focuses on continual improvement of the system

What is the EMS Model?

An EMS follows a Plan-Do-Check-Act Cycle, or PDCA. The diagram shows the process

of first developing an environmental policy, planning the EMS, and then implementing it.

The process also includes checking the system and acting on it. The model is continuous

because an EMS is a process of continual improvement in which an organization is

constantly reviewing and revising the system.

This is a model that can be used by a wide range of organizations from manufacturing

facilities to service industries to government agencies.

What are some key elements of an EMS?

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Policy Statement - a statement of the organizations commitment to theenvironment

Identification of Significant Environmental Impacts - environmental attributes of

products, activities and services and their effects on the environment

Development of Objectives and Targets - environmental goals for the

organization

Implementation - plans to meet objectives and targets

Training - instruction to ensure employees are aware and capable of fulfilling

their environmental responsibilities

Management Review

Can existing environmental management activities be integrated into

the EMS?

Yes. An EMS is flexible and does not require organizations to necessarily retool their

existing activities. An EMS establishes a management framework by which anorganizations impacts on the environment can be systematically identified and reduced.

For example, many organizations, including counties and municipalities, have active and

effective pollution prevention activities underway. These could be incorporated into the

overall EMS.

ENVINRONMENTAL AUDITINGis an integral part of environment

management system whereby management determines whether the organization

environmental control system are to adequate ensure compliance regulatory

requirements and internal polices

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PURPOSE OF DOCUEMENT

The purpose of this document is to provide a basic

Introduction to environmental auditing and its related

Activities. The text has been purposefully written for a

Wide audience and sets out to explain and discuss some

Of the key activities in environmental auditing.

The document also provides insights into different types

of non-financial auditing. It is expected that this

Publication will be of use to academics, advocacy groups,

Civil society groups, environmental practitioners,

Government authorities, Interested and Affected Parties

(I&APs), industry, project proponents, and students.

DEFINATION

ENVINRONMENTAL AUDITINGis an integral part of environment

management system whereby management determines whether the organization

environmental control system are to adequate ensure compliance regulatory

requirements and internal polices

1 to identify actual or potential site contamination

2 Reduce potential environmental liability

3 Basis for further investigation

4 Informed property transactions

5 Identify baseline environmental conditions

6 Meet regulatory requirements

7 Initial step to site remediation

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ENVIRONMENTAL AUDITING

The International Chamber of Commerce defines the "environmental

audit" as follows:

The systematic examination of the interactions between any business operation and its

surroundings. This includes all emissions to air, land, and water; legal constraints; the

effects on the neighboring community, landscape and ecology; and the public's perception

of the operating company in the local area. Environmental audit does not stop at

compliance with legislation. Nor is it a 'green-washing' public relations exercise. Rather it

is a total strategic approach to the organization's activities.

NEED FOR ENVIRONMANTAL AUDITING

Mamagement priorties

Commercial intention

Management system requiremnet

Requrlatory requirient

Supplier evalution

Customers requirements

Pontential riskto the business

MOST PROMINENT PRINCIPLES OF AUDITING:

INDEPENDENCE for basic understanding and reliablity of the audit

ETHICAL CONDUCT:the fonduation intergarity and profeesional ststus

FAIR PRESENTATION of the report

EVIDENCE the ratinal basis of reaching audting conculsion.

DUE AUDIT CARE reasonabLe care in all matters and competeness in

the

presentaion of report

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TYPES OF ENVIRONMENTAL AUDITING

Compliance audit - the most common type of audit consisting of checks againstenvironmental legislation and company policy;

Issues audit - an evaluation of how a company's activities relate to an

environmental issue or (e.g. global pollution, energy use) or an evaluation of a

specific issue (e.g. buildings, supplies);

Health and safety audit - an assessment of risks and contingency planning

(sometimes merged with environmental auditing because of the interconnected

impacts of industrial processes and hazards);

Site audit - an audit of a particular site to examine actual or potential

environmental problems;

Corporate audit - an audit of the whole company and its polices, structures,

procedures and practices;

Due diligence audit - an assessment of potential environmental and financial

risks and liabilities carried out before a company merger or site acquisition or

divestiture (e.g. contaminated land remediation costs);

Activity or operational audit - an assessment of activities that may cross

company departments or units (e.g. energy or waste management) and

Product or life cycle audit - an analysis of environmental impacts of a product

throughout all stages of its design, production, use and disposal, including its

reuse and recycling (cradle to grave).

External audit - 'An assessment of the condition of the local environment, usuallyresulting in a State of the Environment Report (SoE or SOER)'andinternal audit - consisting of two areas:

'Policy Impact Assessment - a review of the activities (objectives, services,practices and policies) of the authority' and

'Management Audit - a review of the procedures and structures by which

environmental policies are managed by the authority'

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DEVELOPMENT OF ENVIRONMENTAL AUDITING

Development of Safety, Health, Environment, and Quality

Auditing

Non-financial auditing has developed as a business management tool and has resulted in

the proliferation

of audits in the annual calendars of various companies. Many companies have made the

decision to combine Many companies have made the decision to combine non-financial

audits such as health, safety, environment non-financial audits such as health, safety,

environment and quality in an effort to reduce costs, disruption and and quality in an

effort to reduce costs, disruption and and quality in an effort to reduce costs, disruption

and inconvenience in the workplace. This approach has both advantages and

disadvantages. The advantages include the fact that there are fewer audits and less

likelihood of reduced productivity in the workplace. A disadvantage would be that by

combining a number of audits, this could dilute the focus on the

Environmental Auditing

Individual components. If this were balanced by increasing

this would then begin the length of time of the audit, this would then begin to increase the

disruptive element of the audit which may affect productivity. The negative effect of the

audits could be reduced if companies were to be able to utilise the added value from the

audits which normally result in reduced wastage, reduced risk, improved performance

and reduced incidents. It is not always possible to financially quantify these benefits and

so the perception still remains that audits are time consuming and interfere with

production.

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Emergence of Sustainability Auditing and

Corporate Social Responsibility

The broadening of the scope of environmental auditingto include Triple Bottom Line or sustainability auditing to include Triple Bottom

Line or sustainability auditing Line concept puts forward the idea that the corporate

sector should not focus solely on the financial bottom line of profit, but also consider

social bottom lines and environmental bottom lines and incorporate these into their

accounting structures. and non-financial auditing and this has been noted in practice by

companies who have attempted to undertake broader based auditing exercises. For

example, many aspects of the social part of the Triple Bottom Line are more difficult to

quantify which creates a problem when contrasted with the more precise financial

auditing structures. Auditing guidelines for sustainability auditing have been developed

to measure and monitor Triple Bottom Line performance (GRI, 2002). The Global

Reporting Initiative (GRI) Guidelines provide the corporate sector with a model for

Tripe Bottom Line accounting and business organisation. Included in these guidelines

is a procedure for auditing compliance to the sustainability model.

Environmental Auditing Programmes

In South Africa detailed guidelines on managing an environmental audit programme can

be found in South African Standard Guidelines for quality and/or environmental

management systems auditing (SANS19011: 2003 Edition 1, ISO 19011:2002 Edition 1).

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ENVIRONMENTAL AUDITING PROCESS

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PICTUIRIAL VIEWS

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Components of an Audit

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The Risk Assessmentidentifies relevant risk factors that challenge an organizational

area and further considers their relative significance.

The Scope Statement identifies the activities that will be covered during the course of

the audit. This would include the project justification, the project description, the

deliverables, and the success criteria.

Audit Program is the document that contains the listing of audit procedures as well as

the objectives of the audit.

Audit Procedures are the specific tasks that the auditor will follow to gather, analyze,

and document during the audit.

Work papers are the detailed documentation from interviews and testing that were

conducted to complete the audit program. OACP is utilizing the latest technology and is

using electronic work papers.

The Deliverables

Interim updates are provided to the auditee throughout the course of the audit. The

observations accumulate into the final audit deliverables, which is the closing

documentation that is provided to the auditee at the completion of the audit. This can be

in the format of a written report that includes observations and recommendations or it

could be in the format of process flows. The purpose of the audit will determine the

format of the final deliverables.

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SECOND STEP

CONDUCTING ENVIRONMENTAL AUDITING

Planning an Environmental Audit

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Any premises that wishes to conduct an environmental audit must have a clear idea of the

objectives of the exercise and the steps required to achieve it. Before commencing an

environmental audit, the following requirements must be fulfilled:

COMMITEMENTS

Obtain commitment at the Directorate level

Communicate commitment to personnel at all levels

DEFINE AUDITING SCOPE

Audit site and boundary

Audit objective(s)

Areas of audit

Audit objectives typically entail:

Verification of legislative and regulatory compliance

Assessment of internal policy and procedural

conformance

Establishment of current practice status

Identification of improvement opportunities

Areas of audit normally encompass:

Material management, savings and alternatives

Energy management and savings

Water management and economy of use

Waste generation, management and disposal

Noise reduction, evaluation and control

(internal and external)

Air emissions and indoor air quality

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Environmental emergency prevention and preparedness

Transportation and traveling practices

Staff awareness, participation and training in environmental issues

Environmental information publicity

Public enquiry and complaints response

Environmental management system set up, suitability and performance

Conducting an Environmental Audit

An environmental audit is typically undertaken in three phases:

Pre-audit

On-site audit

Post-audit

Each of these phases comprises a number of clearly defined Objectives, with each

objective to be achieved through specific Actions, and these actions yielding results in the

form of Outputs at the end of each phase.


PRE-AUDIT

Objectives

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To develop an audit plan for the on-site activities

To make the necessary preparation and arrangements for the on-site audit

Actions

DEVELOP A PLAN

The Audit Plan should address:

Where:audit site & boundary with overview

What: scope & objectives

How: site personnel interview, site inspection, audit protocols; site logistics and administrativearrangement

Who: audit team and site facilitation arrangement

When: audit schedule and milestones

The Audit Team is subsequently to:

Seek agreement from AMC on audit plan Establish the reporting structure


ON-SITE AUDITING ACTIVITIES

Objectives

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The on-site audit objectives should reflect those of the environmental audit, which are:

Verification of legislative and regulatory compliance

Assessment of internal policy and procedural conformance

Establishment of current practice status

Identification of improvement opportunities

Actions

OPENING MEETINGS

Conduct on-site audit Opening Meeting with Office manager and site personnel to:

Introduce audit team members

Present audit scope and objectives

Outline the audit approach and methodology

Address questions or concerns of site personnel

Rally staff support and assistance

DOCUMENTS REVIEWS

Audit Team member to undertake a review of relevant document such as:

Management policy

Management system documentation

Operational procedures

Records (utility, inventory, monitoring, calibration, transportation, training etc.)

Previous audit reports

Green management team meeting minutes

Green suggestions

In particular, to evaluate whether the records are:

Current

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Properly completed

Signed and dated

Consistent

Meet relevant requirements


POST AUDIT ACTIVITES

Objectives

To produce an Audit Report with audit findings and recommendations To contribute towards formulation of an Action Plan for continual performance

improvement

Actions

COLLATE INFORMATION AND FALLOW UP OUTSTANDING

ISSUES

Information to be organized should include:

Completed pre-audit questionnaire, operational document checklists

Completed on-site survey questionnaires, on-site audit protocols

All relevant correspondence, memoranda, reports, diagrams and drawings

Copies of records, photographs, and other information collected during the site

visit

Detailed inspection and interview notes and summaries

Following up an Environmental Audit

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DEVELOP ACTION PLAN

Upon endorsement of the Audit Report, an Action Plan with the appropriate targets and

objectives for environmental improvement may be developed in consultation with audit

site senior management.

An action plan should cover:

Action objectives;

Specific actions required;

Responsible party(ies);

Budget allotted; and

Implementation program

IMPLEMENT ACTION PLAN

Responsible party(ies)to undertake actions according to the allotted budget, and the

agreed timescale for completion.

CHECKING AND MONTORING

To monitor progress of Action Plan implementation, a status report should be

carried out and should include information on:

Progress of action(s) undertaken

Problem(s) encountered when action(s) taken

Proposed solution(s) and revised timescale for completion

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REVIEW A ACTION PLAN

Review the Action Plan upon completion of Action Plan implementation.

Key points to review include:

Review results of action plan implementation

Establish levels of performance improvement achieved

Address possible need for changes to Green management policy, objective(s) and

procedure(s)

Next audit scope and schedule

THRID STEP

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Roles, Responsibilities and Activities within


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Detailed information on this topic can be found in the South African Bureau of Standards

(SABS) ISO 14001:1996, Guidelines for Environmental auditing, Audit procedures and

auditing of environmental management systems. The information presented below is

provided as broad guidance.

Lead Auditor

The lead auditor is responsible for the organisation and management of the audit and

liases with the client or the contact person in the case of an internal audit. The lead

auditor is also responsible for the organisation, recruitment and management of the audit

team and ensuring that the necessary deliverables from the audit, including the audit

report, are delivered according to the agreed timetable and plan.

Auditor

The auditor will undertake auditing tasks, alone or as a member of a team, and must be

conscious of the ethical and professional responsibilities of his task. This will and

professional responsibilities of his task.. This will include ensuring that the audit work is

thorough, fair

and accurate.

Technical expert

In some cases, a technical expert will be included as a part of an audit team to assist with

understanding and interpreting technical aspects of the operation or site being audited.

The technical expert does not necessarily being audited. The technical expert does not

necessarily have to be an auditor but it does help.

Audit team

The audit team must work together, under the leadership of the lead auditor, to ensure

completion within the of the lead auditor, to ensure completion within the brief and scope

of the audit. The team must be mindful that their activities could disrupt the normal

operations of a site or plant and therefore must minimise the negative impact of their

inquiries.

Client

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The client is the individual or organisation that commissions the audit. In the case of an

external audit,

it may be the Chief Executive Officer of a company or the Environmental Manager. In

the case of an internal audit, it could be the departmental head or the Audit Manager. The

client and auditee can sometimes be thesame individual, depending upon the structure

and system within an organisation or company

Auditee

The auditee is, nominally, the person who answers thequestions put by the audit team and

supplies the necessarysupport data and evidence to back up verbal responsesto questions.

In practice, the auditeesrole is to managethe logistics of the audit.

Auditor Competency and Certification

Currently, the only South African organisation that is providing a formally recognized

certification and competency framework for environmental auditors istle Southern

African Auditor Training and Certification Association (SAACTA). SAACTA has

established an Environmental Management System (EMS) Auditor Certification and

Registration Scheme (see glossary reference for SAACTA for further details). There are

alsoa number of private service providers who provideenvironmental auditor training

which includes theprovision for registration with overseas environmentalauditor

registrationandcertificationbodies such as theUK-based, Institute of Environmental

Management and

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Outline of a simplified model for planning an audit

* Clarification of audit scope and brief

* Pre-audit meeting with auditee

* Second pre-audit meeting to clarify points and logistics (optional)* Audit team meeting (optional)

* Audit

. Opening meeting

. Site tour

. Questioning, documentation review, consolidation of findings

. Exit meeting

* Draft Audit report

* Final Audit report

* Audit findings Action Plans

* Next audit

Environmental Audit Reports

The format and content of an environmental audit report will vary enormously, according

to the scope of the audit, the requirements of the client and the context of the audit. The

reports should be kept initially as simple and as readable as possible. The most basic of

audit reports consists of two columns headed Findings and Recommendations and

each finding is linked to a

Specific question or heading taken from the audit protocol. This can be made more

manageable by including an executive summary at the beginning and the detail in the

report can develop from here onwards. Guidelines for formal audit report format and

content can be founding ISO 19011:2002 Guidelines for quality and/or environmental

management systems auditing. Box 2provides an example of the generic contents of an

audit report.

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SOME OF THE TOOLS AND TECHNIQUES

USED IN AUDITING

Checklists

Checklists are very useful tools to use to ensure that different tasks or topics are includedduring the audit. They are very useful in specialized cases where a complex range of

issues and questions need to be asked to ensure that nothing is missed. One of the

limitations of checklists is that there is tendency to rely too much on a checklist and not

look at matters that arise beyond the contents of the checklist

or secondary questions and issues that may develop asa result of other information or

observations. A checklist

Example of the contents of an audit report

Executive summary

* Key findings and commentary

* Commentary on site tour and photographs

* Full list of all recommendations

Scope of Audit

* Areas audited, site location, audit focus

Date of audit and participants

Detailed report

* Sections based upon topics covered in audit protocol

Conclusions and Recommendations

Appendices

* Copy of audit protocol

* Photo log

* Supporting documentation (may be included in a separate volume)

with all the sections carefully ticked off is not necessarilya true reflection of, say, a fullycompliant site. If questionsor check items have, for some reason, been left off

orforgotten, this could have a significant impact upon theconclusions of the audit. It is for

that reason thatadditional information needs to be used in support ofchecklists.

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Questionnaires (Audit Protocols)

Audit protocols or audit questionnaires provide the basis and structuring for most audits.

They are based upon checklist questionnaires but are more complex and include more

detail and sometimes logistical information and data relating to the audit and the site

being audited. When developing protocols, every effort should be made to avoid

generating questions that can be answered bay simple yes or no. The purpose of

questions in protocols is to trigger supplementary questions, additional information not

specifically asked in the question and encourage a two-way dialogue.

Questioning

Questioning is one of the most crucial aspects of auditing yet from a training and

awareness point of view, it soften given the least attention. Questions should be posed in

a neutral, friendly manner to prevent theauditee feeling defensive or threatened by the

nature and content of the questions. The purpose is information gathering in nature and

not an interrogation. The questioner must therefore be sensitive to the perspective of the

auditee and avoid making the questions accusatory,

judgmental or aggressive.

Observation

Observation is a vital component of an auditing exercise. Observation is a disciplined

activity which must be carried out in a very deliberate and controlled manner. Human

behaviour being what it is, there is often a tendency to see what we want to see rather

than see what is there. Similarly, one may make an observation and see fragmentary part

of a scene or activity and assume the rest, rather than checking the entire scene. The idea

of looking at something twice is important because it is part of the process that checks

that the observation inaccurately noted, analyzed and recorded.

Photographs

Photographs are a very valuable aid in the audit process. However, in order to use them, a

number of important practical points must be borne in mind. The first point is that formal

approval to bring a camera

on to site for the audit must be obtained before the audit begins.

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Drill Down Sampling

Drill down sampling refers to the process of investigating data as far back as possible,

going right back, for example, to the point where the operator read the pressure dialed

wrote the reading down on a clipboard. It is necessary, on a sampled basis, to drill down

to information or action source in a number of situations to check whether a system is

working and that the data being generated through the systems requirements is actually

being generated, recorded and utilised. Generally, as one finds more errors, faults and

nonconformances ,one tends to increase the size and scope of the drill down sampling to

explore whether the problems are of an isolated nature or whether they reflect a systems

breakdown.

Research

It is useful to try and undertake some background research and investigation into the site

or company to be audited .Familiarization with the operations, products, raw materials

reports, press material and newspaper articles all provides useful background information

to supplement questioning sessions and help understand the operational processes.

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THE PRACTICALITIES OF ENVIRONMENTAL

AUDITING

Psychology of auditing

Psychology is the heart of good auditing. If the people management of auditing (i.e.

auditors and auditees) is done correctly, then the information generated fromthe audit will

be of a high quality and value added. The following important points need to be borne

in mind.

Fear of the unknown

Many people fear the unknown and audits often fall into this category. The reaction to the

unknown is to become defensive and suspicious of all questions and queries. If auditors

present themselves as open and transparent, this contributes towards better co-operation

and communication.

Home Territory

If the auditor recognizes that he is venturing on to someone elses home territory, and

gives appropriate respect and recognition to the superior status that fact places upon the

auditee, then there is greater impetus on the part of the auditee to share his knowledge

and expertise and be magnanimous and free in his sharing of information and experience

during the audit.

Emotions

The auditor needs to recognise that he may be subject to a wide range of emotions which

are a defense to the audit and what it may bring upon the auditee. Anger, aggression, and

fear are all reactions to an audit,

Particularly if the audit has been imposed on a site by head office or if the auditee

has the view that audits are a waste of time. If the auditor spends time explaining,

reassuring and informing the auditee of what the audit is about and how it can benefit the


Use of the Pre-audit meeting

The pre-audit meeting is an ideal opportunity to create positive view of the audit event by

the auditee. If the auditor lays all the facts out on exactly what the audits about, why it is

being carried how it will be carried out, how the results will be used, the benefits, the

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questions that will be asked and exactly what is to happen, then the auditee has less to

fear. Furthermore, the auditee will feel more confident and willing to co-operate. It is

important to encourage the auditee to ask questions about the audit process and

deliverables to ensure that there is willingness to volunteer all the necessary information

to make the audit a success.

Policing versus Continuous Improvement

Experience has shown that if auditor and auditee work together and share their respective

knowledge and experience, both can benefit from the audit exercise .Auditees are often

consciously, and sometimes unconsciously, aware of the environmental issues and

concerns that need to be addressed in a particular factory, operation or site. By

persuading the auditee to share those perspectives with the auditor more detailed

information and insights can be acquired. If the auditor presents himself as a policeman

looking for errors or faults, the psychological response of the auditee will be to hold back

information for fear of being penalised for doing things wrong. It has been shown

frequently that the practical suggestions, alternatives, and observations that have resulted

from audits have added positive value to the audited organization. An outside view,

perspective and opinion often helps staff who have been too close to problems or

methods to see the value of alternative approaches. An audit report is a very powerful and

valuable communications tool to use when working with various stakeholders who needto be convinced that things are running smoothly and systems and procedures are coping

with natural changes and modifications that occur.

A Snapshot in Time

It is important not to lose sight of the constraints associated with environmental audits.

They are essentially snapshots in time. In other words, they reflect a situation and

assessment at the time that the audit was conducted. Circumstances will change as

activities and developments in the audited operation change. An audit merely samples

activities and systems and reflects the status at a particular point in time. It gives

indications, suggestions, directions and options, it does not solve problems. Problem

solving develops from the findings and recommendations of an audit.

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ENVIRONMENTAL AUDITING AND DECISION-

MAKING

Transparency

An environmental audit report is one of the useful means of demonstrating an

organizations commitment to openness and transparency. If an organization believes it

has nothing to hide from its stakeholders, then it should feel confident enough to make

its environmental audit reports freely available to those who request them.

Audit report distribution

As a basic rule, environmental audit reports should be made available to all stakeholders.

In such circumstances, the information contained within the report should be written in

such a manner that all stakeholders are able to understand it. Should the report be

excessively technical, there should be non-technical summaries or appendices included.

Some reports are specifically written for internal organizational consumption and for use

as baseline information and guidance for the purpose of continuous improvement. At the

commencement of the audit process, it is advisable to ascertain who the potential

audience of the audit report will be and to get consensus on the format, content,

circulation and status.

ConfidentialityThe external auditor is an outsider and, as such, must be given access to strategic,

sensitive and proprietary company information in order to be able to carry out the audit.

In order to protect proprietary company secrets and information that ensures a companys

competitive advantage, an external auditor may be required to sign some form of secrecy

agreement to reinforce the need to safely manage information during the course of the

audit. As a basic principle of professionalism, the auditor should keep all information

gathered confidential, unless given permission to release information by the client.

Participation of Stakeholders on Audits

Stakeholders such as neighboring communities are often very suspicious of the industrial

operations that they live next to. This suspicion often stems from a lack of knowledge and

understanding of what goes on inside the factories and sites. Inviting representatives of

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these neighbouring communities to participate in the routine internal audits, and even the

less frequent external audits, is a means of demonstrating good faith and

openness.

Audit Follow-up

Audits are exercises which generate considerable quantities of valuable management

information. The time and effort and cost involved in this exercise is often considerable

and in order to be able to justify this expenditure, it is important to ensure that the

findings and recommendations of the audit are considered at the correct level within the

organization and that action

plans and implementation programmers result from the findings. Audit follow up is part

of the wider process of continuous improvement. Without follow-up, the audit becomes

an isolated event which soon becomes forgotten in the pressures of organizational

priorities and the passing of time.

Auditing and Formal Systems

Many companies are taking the route of establishing environmental management systems

which are based upon the ISO 14001 standard for EMS. The choice of whether to

actually certify the system formally independent upon cost benefit and associated demand

from customers and clients. Whilst it may be seen to be desirable to certify, many

organizations will align their internal environmental management systems to ISO

14001and delay the formal certification until there is a business

motivation to certify. The ISO 14000 series contains a number of standards

Which expand upon the primary ISO 14001 system, notably SO standards 14004

(General guidelines) 14010 (Auditing principles), 14011 (Audit procedures), 14012

(Auditor qualification criteria), 14041 (Life Cycle Analysis) and14050 (Vocabulary).The

voluntary European Eco-Management and Audit Scheme (EMAS) is an initiative

designed to improve companies environmental performance. It is generally agreed to be

more rigorous that ISO 14001.

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CASE STUDIES

NATIONAL INDUSTRIES, EDAYAR

Name of the Industry : National Industries, Edayar

Date of Inspection : 04-11-2004

Name of the Product/s : Animal bones- 4 tonnes / day

Products : Crushed bone- 3 t/day

: Bone meal - 0.75 t/day

: Tallow- 80- 100 kg / day

: Sinews- 40 50 kg / day: Organic fertilizers -100 kg/day

Process:

Raw bones received will be stored in a storage area and are dried by steam and tallow is

separated. Waste water from the boiler is mixed with ash and separated as organic

fertilizer.

The bones are crushed into pieces. Crushed pieces are dried and introduced to vibrator

screen

where bone meal and sinews are separated as final product.

Findings:

The Unit has obtained Air Consent valid upto 19-05-2005. This unit is situated very near

to

the river Periyar and as a special condition no 16 of the consent there should be a buffer

area

of 20 meters to be kept free from any construction and this unit has no construction upto

approximately 10 mts but 20 mts is not left free. Wet bones as raw material is stacked in

a

floored and roofed shed with ventilation around at top. This unit is using a boiler/reactor

for

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steaming and the tallow extraction. General house keeping is in a pathetic condition.

There is

no confined drain to tackle the rain run off. There is a drain outside the unit, which is let

into

the River Periyar without any treatment. This is an unauthorized outlet into the River

Periyar

and should be removed immediately.

Recommendations:

1. All conditions stipulated in the consent under the Air Act issued by the KSPCB

should be strictly complied.

2. Chimney of height 15 metres from the ground level has to be provided, with sufficient

draft using blower/ fan so as to have the appropriate exit velocity to provide

dispersion and dilution of the nuisance smell, in the raw bone storage enclosure or

should provide appropriate bio filter to contain the nuisance gas coming out from the

storage. The blower/fan should have a separate electricity meter to measure current

used.

3. There should not be any tallow extraction and any liquid effluent.

195

4. The storage area should not produce any leachate and such leachate if any should betreated before discharge.

5. There should be confined rain water drain and no liquid effluent, leachate or

putrefiable matter should be carried by the drain. If such , the discharge from the

drains should be treated.

6. Raw materials should be protected from birds using nets coverings.

7. Effective Bio-filter should be installed for odour control within one month.

8. Raw bones brought to the Unit shall be processed on the same day itself.

9. Crushing of bones, storing, packing, loading and unloading shall be done in an

enclosed area.

10. The Unit must be directed to submit ambient air quality analytical reports to the PCB

at least once in three months.

11. The Unit shall be directed to plant suitable species of trees along the periphery of the

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factory premises, forming a green belt to improve the environment

12. The Unit must be directed to implement good house keeping systems.

13. The Unit should be directed to ensure better Occupational health and safety of its

workers.

14. Sign board showing the name of the Unit shall be displayed at the entrance of the site.

15. The Unit has not complied with Condition no. 16 viz., maintaining of a buffer of 20

metres wide land in the premises of the Unit in the side of Periyar River. This must

be complied forthwith and structures within this area shall be dismantled.

16. The unauthorized storm water outlet, which opens directly into the River Periyar,

shall be directed to be sealed forthwith.

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HI- TECH SEALS (P). LTD.Name of the Industry :Hi- Tech Seals Pvt. Ltd.

Date of Inspection : 16-11-2004.

Name of the Products : Fuel Tank 15Nos

Wheel Rim 11 nos

Radiator Cover 8 ,,

Mudguard Plate 7 ,,

Spiral Wound Gasket 45 nos

Raw materials : CRCA Sheet 26.2 kg

Stainless Steel Strips 10 kg

Paint

Rings

Graphite Tape. 500 metre

Process:

Engineering works of cutting, drilling, punching, welding, acid treatment, rinsing,

phosphating followed by spray painting in painting booth.

Waste:

Waste water generated from Acid treatment, rinsing and phosphating constitute the liquid

effluent and is let out into land without any treatment. The waste material metal scrap (20

kg/day) is disposed by sale.

Findings/ Recommendations:

1. Adequate facility is not provided for treating the waste water generated from the

plant.

2. Pollution control measures provided at the paint booth is inadequate.

3. The unit is not having the Boards consent under the Water Act and Air Act. The

unit should provide adequate air and water pollution control measures and obtain the

Boards consent.

184

4. The acidic waste from pre treatment and sludge from phosphating comes under the

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hazardous waste category. The unit has no authorization under the Hazardous Waste

(Management and Handling) Rules 1989

5. The Unit operates without any consent viz., Hazardous Waste (Management and

Handling) Rules 1989; Air Act and Water (Prevention and Control of Pollution) Act

1974.

6. The Unit is given time one months time to obtain all required consent and

authorization, failing which the Unit will be directed to stop production.

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COCHIN RUBBER INDUSTRIES, EDAYAR.Name of the Industry : Cochin Rubber Industries, EdayarDate of Inspection : 15.02.03 & 22.02.03Name of the Product/s : Crepe rubberRaw materials : Scrap rubber

Waste7500L/day waste water generated is discharged into land after passing through rubbertraps.

ProcessScrap brought to the factory is soaked in water to remove dirt and stonesThe scrap is then pressed through a series of rollers with sprinkling of water.The product is dried in air.

Findings/Recommendations :1. Effluent under anaerobic condition is seen stagnant in ponds in the premises. There isno facility for Effluent treatment. Scrap waste solids are dumped in the premises ofcollection tanks. Due to putrefaction and open land discharge, the entire area isuntidy. Proper Effluent treatment plant should be set up for treating the effluent.2. The consent issued by the Board under the Water (Prevention and Control ofPollution) Act, 1974 has expired w.e.f. 31.12.04. It is shocking to note that in thesaid, the KSPCB has allowed the Unit to discharge trade effluent into open land.

The Unit is therefore, discharging the trade effluent into open land including to theadjacent low-lying areas.3. Effluent from the premises is seen dumped in the adjacent property through anunderground pipe, where it gets stagnated.4. The Unit should be directed to set up proper ETP system and obtain the Boardsconsent within one months time, failing the Unit shall be directed to be closed down.5. The Unit must be directed to re-use the treated effluent and not to discharge it into theopen land.6. The Unit must be directed to forthwith stop discharging untreated effluent into openland and to the nearby low-lying areas.7. Unit must be directed to improve the house keeping.8. The Unit must provide a green belt, with fast growing and long lasting trees in itspremises.210

Consented Parameters and LimitsConsented parameters under Water(Prevention and Control of Pollution)Act 1974.SL.No Characteristic Unit Tolerancelimit1 pH 6-82 BOD(3Days at 270 C) mg/l 303 Oil and Grease ,, 104 Suspended Solids ,, 100

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Colour Code

Red: Pollutants not conforming to the standards stipulated in consent order.Pink: Pollutants in effluent not included in consent orderDark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.

Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.

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Shell Criticized for Manipulating Environmental AuditReport

Shell is accused of manipulating an independentenvironmental audit by AEA Technology to determine whether an oil and gas projectwould receive bank funding, Guardian reports.

Dozens of e-mails secured through the Freedom of Information Act show how Shellofficials in London attempted to downplay and edit environmental criticism of the $22billion Sakhalin II energy scheme. Officials persuaded AEA to disperse its findingsthroughout the report, rather than leaving them in one appendix. Also downplayed wereexperts concerns over the impacts of continuous noise on endangered whales, andquestions about whether permits were sought before or after drilling began.

In addition, the AEA report lists Sakhalin Energy as its client, even though the audit wassupposed to be independent.

In August, Shell was reprimanded by UKs Advertising Standards Authority forviolating

advertising rules when it claimed that two oil projects in Canada and the U.S. involvedsustainable forms energy.

44
http://www.guardian.co.uk/business/2008/aug/31/royaldutchshell.sakhalinhttp://www.environmentalleader.com/2008/08/14/asa-shell-environmental-claims-violate-advertising-rules/http://www.environmentalleader.com/2008/08/14/asa-shell-environmental-claims-violate-advertising-rules/http://www.guardian.co.uk/business/2008/aug/31/royaldutchshell.sakhalinhttp://www.environmentalleader.com/2008/08/14/asa-shell-environmental-claims-violate-advertising-rules/http://www.environmentalleader.com/2008/08/14/asa-shell-environmental-claims-violate-advertising-rules/


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REFERENCES

FROM INTERNET AND BOOKS

Cahill, L.B. (2001) Environmental Health and SafetyAudits, 8th Edition, Government Institutes, Rockville.Cheremisinoff, P.N. and Cheremisinoff, N.P. (1993)Professional Environmental Auditors Guidebook,NoyesPublications, New Jersey.Cox, Y. (2002) A Step-by-Step Guide to Providing Accessto Information, Updated July 2003, LexisNexisButterworths, Durban.Greeno, J.L., Hedstrom, G.S. and Diberto, M. (1987)

Environmental Auditing: Fundamentals and Techniques,2nd Edition, Arthur D Little Inc, Cambridge.Greeno, J. L., Hedstrom, G.S. and Diberto, M. (1988) TheEnvironmental, Health, and Safety Auditors Handbook,

Arthur D Little Inc, Cambridge.GRI (2002) Global Reporting Initiative 2002Sustainability Reporting Guidelines,

www.globalreporting.orgHarrison, L. (1995) Environmental, Health, and SafetyAuditing Handbook, 2nd Edition, McGraw-Hill Inc., NewYork.

Hess, K. (1997) EH&S Auditing Made Easy A ChecklistApproach for Industry, Government Institutes, Rockville

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