Environmental audits can be very intimidating experiences for any EHS manager. You may constantly wonder if you missed something, or if a worker did something somewhere that they didn’t report and you never even knew about.
“Stressful” is an often an understatement when it comes to environmental audits. So, how can we flip this situation around and start making the most of these events to improve our facility? Now that we’re well into 2013, it’s time to put the Auld Lang Syne spirit to work and start some new relationships off on the right foot, specifically the way you approach your environmental regulators and auditors.
ERA Environmental Management Solutions’ team of environmental experts was tasked with putting their heads together to offer up the best advice for EHS professionals seeking to make the New Year as stress-free and profitable as possible. They all agreed that the best route was to flip your mode of thinking and finally make friends with your auditors.
What’s Your Auditor Attitude?
When we talk to EHS professionals, they often view their local compliance auditors not as an ally, but as an obstacle to their success. In some cases, even a nuisance.
There’s a perception that auditors sweep into facilities looking for any tiny slip-up to punish managers for with hefty fines. Rather than considering auditors as professionals with the responsibility of ensuring environmental and safety standards are met, some EHS professionals subconsciously demonize their auditors and make routine audits into stressful affairs.
In reality, those EHS professionals who dislike their auditors are the ones with the biggest headaches before and during audits, and often feel the most miserable as a result. Yes, inspections and audits can be stressful, especially after new regulations are implemented or when there’s regulatory uncertainty in your sector, but expecting the worst of your auditors puts up barriers that are detrimental to your own success.
If you don’t trust your regulators to be acting in everyone’s best interest, you’re less likely to be completely transparent and that is something a good regulator is trained to see as a red flag. If you don’t respect your auditors, you’re less likely to worry about keeping clear audit trails in your recordkeeping, which only hurts your business in the end. And even if you just tolerate your auditors’ presence, it’s unlikely they’ll come to see you as a manager truly dedicated to employee safety and well-being.
In short, your attitude towards your local auditors and regulatory officers reflects how you prioritize your EHS data management and determines how your auditors will see you.
Auditors as Allies
Here’s the truth about auditors: They want you to succeed and hate doling out noncompliance fines. They want to keep your workplace as safe and profitable as you do. In fact, having an environmental or safety auditor on your side can be one of the most useful resources you’ll ever have access to.
Auditors and regulators see firsthand all those frequent reporting errors and little-known mistakes that reporters make that end up costing them time and money. For example, you should always check with your local regulators to see if the De minimis exemption applies to your state, as this common error is the source of many inaccurate emission reports and fines.
Because auditors hate seeing mistakes as much as you hate making them, they will go the distance in helping you avoid them. That means they are the best people to go to for advice on how to properly fill out a standardized annual report and to get alerted to common pitfalls other reporters fall into, like failing to get the proper pages signed correctly.
The best online resources and documents about avoiding common errors in reports also typically come from regulatory offices themselves.
While befriending your auditors is definitely not about trying to get indiscretions overlooked, just having a good rapport with your auditors makes audits less stressful and will allow you to approach them with questions to clarify items you may not be sure about.
It’s all about perception. Instead of feeling like an auditor is grilling you about emission sources, it’s an opportunity for you to show off how well prepared you are, how much your business prioritizes air quality standards and even open things up to suggestions for improvements.
If you don’t expect the worst of your auditors, they won’t assume the worst of you, and that can make all the difference in whether an auditor sees red flags everywhere or just a work in progress.
Improving Your Reputation with Auditors
Getting on your auditors’ good side is not a difficult task, and there’s no mystery to it. You simply have to do your job correctly and be transparent. Some EHS managers incorrectly think that auditors only smile on those businesses with perfect compliance records, but in my experience, the truth is that auditors place just as much value on honesty, effort and hard work toward a clearly defined goal of improvement.
For example, one of our clients experienced an unpredictable and unpreventable equipment failure that resulted in an excess emission of hazardous air pollutants. But because he kept excellent records through the whole event, including tracking all the excess emissions by type and quantity, and then immediately self-reported, his reputation and relationship with regulators came out unscathed. Even better, the auditor that was sent to inspect the facility in the aftermath actually complimented the EHS manager on a job well done because of their commitment to proper compliance management even during a difficult situation. In this case, detailed recordkeeping and a dedication to transparency clearly trumped the accidental excess emissions.
Another common example of honesty winning out is when facilities uncover a small reporting error that regional regulators have overlooked and choose to report the oversight rather than covering it up. In most cases, the regulators are forgiving to honest reporters, but the penalties are much harsher when the EPA discovers the mistake for themselves a few years later.
It also helps to put yourself into the regulator’s mindset when evaluating processes. For example, some businesses choose to do what’s easiest for them when it comes to recordkeeping (like not always getting reports signed or neglecting to write down the results of a daily inspection if there were no issues found), but forget that an auditor is expecting to see consistent recordkeeping with a clear audit trail and signatures.
In all of your EHS data management practices, remember that your auditors may have a different set of expectations and priorities that you need to meet. Most of all, remember to view your auditor as an ally – not an obstacle.
Gary Vegh, co-founder of ERA Environmental Management Solutions, has more than 15 years of experience in providing environmental compliance software for manufacturing companies with complex environmental regulations. Vegh graduated from Concordia University, Montreal, where he studied chemistry/ecotoxicology. He later moved to Research Triangle, N.C., where ERA was founded to meet the compliance needs of the local wood furnishing industry. Today, the company’s clients include Volkswagen, Toyota, Nalco, Vigor and BMW.