Jatin Shori

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INDEX

Contents 1. INTRODUCTION 2. PURPOSE OF THIS DOCUMENT 3. WHAT IS ENVIRONMENTAL AUDITING 4. DIFFERING TYPES OF ENVIRONMENTAL AUDITS Environmental Management Audits Environmental Compliance Audits Environmental Assessment Audit Waste Audits Environmental Due Diligence Audits Supplier Audits 5. THE DEVELOPMENT OF ENVIRONMENTAL AUDITING 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 Checklists Questionnaires (Audit Protocols) Questioning Observation Photographs “Drill Down” Sampling Research 7. THE PRACTICALITIES OF ENVIRONMENTAL AUDITING Psychology of auditing Policing versus Continuous Improvement A Snapshot in Time Quality Control 8. ENVIRONMENTAL AUDITING AND DECISION-MAKING Transparency Audit report distribution Confidentiality Participation of Stakeholders on Audits Audit Follow-up Auditing and Formal Systems 9 CASE STUDY 10. CONCLUSIONS 11. REFERENCES

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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 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.

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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

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Provides a systematic way of managing an organization’s environmental affairs

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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

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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

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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

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Policy Statement - a statement of the organization’s commitment to the environment

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Identification of Significant Environmental Impacts - environmental attributes of products, activities and services and their effects on the environment

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Development of Objectives and Targets - environmental goals for the organization

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Implementation - plans to meet objectives and targets

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

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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”

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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 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

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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

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Commercial intention

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Management system requiremnet

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Requrlatory requirient

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Supplier evalution

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Customers requirements

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Pontential riskto the business

MOST PROMINENT PRINCIPLES OF AUDITING:

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INDEPENDENCE for basic understanding and reliablity of the audit

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ETHICAL CONDUCT:the fonduation intergarity and profeesional ststus

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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

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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;

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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);

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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);

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

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

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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);

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Activity or operational audit - an assessment of activities that may cross company departments or units (e.g. energy or waste management) and

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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

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'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 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).

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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 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

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Communicate commitment to personnel at all levels

DEFINE AUDITING SCOPE •

Audit site and boundary

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Audit objective(s)

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Areas of audit

Audit objectives typically entail: •

Verification of legislative and regulatory compliance

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Assessment of internal policy and procedural conformance

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Establishment of current practice status

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Identification of improvement opportunities

Areas of audit normally encompass: •

Material management, savings and alternatives

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Energy management and savings

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Water management and economy of use

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Waste generation, management and disposal

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Noise reduction, evaluation and control (internal and external)

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Air emissions and indoor air quality 16

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Environmental emergency prevention and preparedness

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Transportation and traveling practices

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Staff awareness, participation and training in environmental issues

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Environmental information publicity

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Public enquiry and complaints response

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Environmental management system set up, suitability and performance

Conducting an Environmental Audit An environmental audit is typically undertaken in three phases: •

Pre-audit

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On-site audit

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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

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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

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

Verification of legislative and regulatory compliance

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Assessment of internal policy and procedural conformance

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Establishment of current practice status

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Identification of improvement opportunities

Actions OPENING MEETINGS Conduct on-site audit Opening Meeting with Office manager and site personnel to: •

Introduce audit team members

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Present audit scope and objectives

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Outline the audit approach and methodology

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Address questions or concerns of site personnel

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Rally staff support and assistance

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

Management policy

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Management system documentation

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Operational procedures

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

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Previous audit reports

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Green management team meeting minutes

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Green suggestions

In particular, to evaluate whether the records are: •

Current

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Properly completed

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Signed and dated

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Consistent

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Meet relevant requirements

Conducting an Environmental Audit POST AUDIT ACTIVITES Objectives •

To produce an Audit Report with audit findings and recommendations

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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

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

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All relevant correspondence, memoranda, reports, diagrams and drawings

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

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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;

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Specific actions required;

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Responsible party(ies);

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Budget allotted; and

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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

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Problem(s) encountered when action(s) taken

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Proposed solution(s) and revised timescale for completion 21

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

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Establish levels of performance improvement achieved

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

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Next audit scope and schedule

THRID STEP

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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

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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 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

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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 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.

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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 DECISIONMAKING 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

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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 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

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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 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

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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 month’s 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, 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.

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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.

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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 decisionmaking.

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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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