1

INDEX

Contents
1. INTRODUCTION 2
2. PURPOSE OF THIS DOCUMENT 6
3. WHAT IS ENVIRONMENTAL AUDITING 7
4. DIFFERING TYPES OF ENVIRONMENTAL AUDITS 8
Environmental Management Audits
Environmental Compliance Audits
Environmental Assessment Audit
Waste Audits
Environmental Due Diligence Audits
Supplier Audits
5. THE DEVELOPMENT OF ENVIRONMENTAL AUDITING 9
Development of Safety, Health, Environment, and Quality Auditing
Emergence of Sustainability Auditing and Corporate Social Responsibility
Environmental Auditing Programmes
Roles, Responsibilities and Activities within Environmental Auditing
Process involved in undertaking an Environmental Audit
Environmental Audit Reports
6. SOME OF THE TOOLS AND TECHNIQUES USED IN AUDITING 25
Checklists
Questionnaires (Audit Protocols)
Questioning
Observation
Photographs
“Drill Down” Sampling
Research
7. THE PRACTICALITIES OF ENVIRONMENTAL AUDITING 28
Psychology of auditing
Policing versus Continuous Improvement
A Snapshot in Time
Quality Control
8. ENVIRONMENTAL AUDITING AND DECISION-MAKING 32
Transparency
Audit report distribution
Confidentiality
Participation of Stakeholders on Audits
Audit Follow-up
Auditing and Formal Systems
9 CASE STUDY 33
10. CONCLUSIONS 43
11. REFERENCES 44

2
 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 for electricity. 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.

3
 Environmental management system (EMS)

Refers to the management of an organization’s 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 organization’s environmental affairs
• Is the aspect of the organization’s 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?

4
 • Policy Statement - a statement of the organization’s commitment to the
environment
• 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 an
organization’s 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 AUDITING is 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”

5
 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 AUDITING is 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

6
 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 against
environmental 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, usually
resulting in a State of the Environment Report (SoE or SOER)'and
internal 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'

8
 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 auditing
to 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).

10
ENVIRONMENTAL AUDITING PROCESS

11
PICTUIRIAL VIEWS

12
Components of an Audit

13
The Risk Assessment identifies 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

15
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.

Conducting an Environmental Audit

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 administrative
arrangement

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

Conducting an Environmental Audit

ON-SITE AUDITING ACTIVITIES

Objectives

18
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

Conducting an Environmental Audit

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

22
Roles, Responsibilities and Activities within
Environmental Auditing

23
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

24
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 auditee’srole 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 auditor’s 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

25
 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.

26
 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 included
during 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 fully
compliant 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 system’s requirements is actually
being generated, recorded and utilised. Generally, as one finds more errors, faults and
nonconformance’s ,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 else’s “ 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
Environmental Auditing
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

30
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 need
to 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.

31
Quality Control
As in any operation, it is vital to ensure that activities and processes during the audit have
some form of quality control to ensure that high standards are maintained. There are
many different means of maintaining quality control and their use will vary according to
the circumstances of the audits undertaken.

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 ENVIRONMENTAL AUDITING AND DECISION-
MAKING
Transparency
An environmental audit report is one of the useful means of demonstrating an
organization’s 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
it’s 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.
Confidentiality
The 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 company’s
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

33
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

35
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 be
treated 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

36
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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38
 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 Board’s consent under the Water Act and Air Act. The
unit should provide adequate air and water pollution control measures and obtain the
Board’s consent.
184
4. The acidic waste from pre treatment and sludge from phosphating comes under the

39
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 month’s time to obtain all required consent and
authorization, failing which the Unit will be directed to stop production.

40
 COCHIN RUBBER INDUSTRIES, EDAYAR.
Name of the Industry : Cochin Rubber Industries, Edayar
Date of Inspection : 15.02.03 & 22.02.03
Name of the Product/s : Crepe rubber
Raw materials : Scrap rubber
Waste
7500L/day waste water generated is discharged into land after passing through rubber
traps.
Process
Scrap brought to the factory is soaked in water to remove dirt and stones
The 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 is
no facility for Effluent treatment. Scrap waste solids are dumped in the premises of
collection tanks. Due to putrefaction and open land discharge, the entire area is
untidy. 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 of
Pollution) Act, 1974 has expired w.e.f. 31.12.04. It is shocking to note that in the
said, 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 the
adjacent low-lying areas.
3. Effluent from the premises is seen dumped in the adjacent property through an
underground pipe, where it gets stagnated.
4. The Unit should be directed to set up proper ETP system and obtain the Board’s
consent within one month’s 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 the
open land.
6. The Unit must be directed to forthwith stop discharging untreated effluent into open
land 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 its
premises.
210
Consented Parameters and Limits
Consented parameters under Water(Prevention and Control of Pollution)Act 1974.
SL.No Characteristic Unit Tolerance
limit
1 pH 6-8
2 BOD(3Days at 270 C) mg/l 30
3 Oil and Grease ,, 10
4 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 order
Dark red: Pollutants in hazardous waste /sludge exceeding limit as per HW Rules.
Blue: Presence of heavy metals/pollutants in hazardous waste/sludge.

42
43
 Shell Criticized for Manipulating Environmental Audit
Report

Shell is accused of manipulating an independent

environmental audit by AEA Technology to determine whether an oil and gas project
would receive bank funding, Guardian reports.

Dozens of e-mails secured through the Freedom of Information Act show how Shell
officials in London attempted to downplay and edit environmental criticism of the $22
billion Sakhalin II energy scheme. Officials persuaded AEA to disperse its findings
throughout the report, rather than leaving them in one appendix. Also downplayed were
experts’ concerns over the impacts of continuous noise on endangered whales, and
questions 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 was
supposed to be independent.

In August, Shell was reprimanded by UK’s Advertising Standards Authority for violating
advertising rules when it claimed that two oil projects in Canada and the U.S. involved
sustainable forms energy.

44
 CONCLUSIONS
Environmental audits can “add value” to the management approaches being taken by
companies and organisationsand is a way of identifying, evaluating and managing
environmental risks (known and unknown). It can be undertaken at various levels of
sophistication and detail which can be tailored to the needs of the client organization .The
current focus on shifting business priorities from just
a financial profit bottom line to a broader “Triple Bottom-Line”. This means that
organizations need to collect more data and evaluate performance on a wider and more
diverse basis. The environmental audit assists in the processor testing performance in the
environmental arena and is fast becoming an indispensable aid to business decision-
making.

45
 REFERENCES

FROM INTERNET AND BOOKS

Cahill, L.B. (2001) Environmental Health and Safety
Audits, 8th Edition, Government Institutes, Rockville.
Cheremisinoff, P.N. and Cheremisinoff, N.P. (1993)
Professional Environmental Auditor’s Guidebook, Noyes
Publications, New Jersey.
Cox, Y. (2002) A Step-by-Step Guide to Providing Access
to Information, Updated July 2003, LexisNexis
Butterworths, 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) The
Environmental, Health, and Safety Auditor’s Handbook,
Arthur D Little Inc, Cambridge.
GRI (2002) Global Reporting Initiative – 2002
Sustainability Reporting Guidelines,
www.globalreporting.org
Harrison, L. (1995) Environmental, Health, and Safety
Auditing Handbook, 2nd Edition, McGraw-Hill Inc., New
York.
Hess, K. (1997) EH&S Auditing Made Easy – A Checklist
Approach for Industry, Government Institutes, Rockville

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