Environmental, health, and safety (EHS) audits: not just a tedious waste of time, although they may sometimes feel that way to managers. On the contrary—EHS audits are vital across industries for a host of reasons—one of the largest of which is regulatory compliance. Not only that, but regularly performing gap analyses and internal EHS audits can help ensure your organization is prepared for both planned and unexpected inspections—before a regulatory agency comes knocking.
Audits and gap analyses assist in passing compliance inspections from:
- Federal agencies like the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA)
- Municipal fire department
- Accreditation organizations (The Joint Commission, The International Organization for Standardization (ISO), etc.)
- Other state and local enforcement bodies like state Departments of Environmental Protection (DEP) and Conservation (DEC)
No matter the agency or regulatory body, preparedness is the top way to impress inspectors—and only by being prepared will you succeed.
EHS audits are pivotal in determining the health of your regulatory and/or safety programs. They are designed to be all-encompassing, thorough, and can be a methodical way to collect data and evaluate if your organization is complying with applicable regulations and industry standards. Audits can focus on individual sites or the organization as a whole. EHS audits may be preplanned, with an announced date—or an auditor may show up at your facility unexpectedly and require you to show evidence of compliance.
EHS audits help ensure:
- Inspection preparedness
- Operational improvement opportunities and corrective actions
- A safe work environment
- Brand reputation and competitive advantage
Ultimately, in your audits, you want to determine the standard you’re trying to meet (e.g., Personal Protective Equipment (PPE) Compliance, Fall Protection, Laboratory Standard, Bloodborne Pathogen Standard, Fire Safety), then determine if you meet its conditions. An audit will indicate if you’re aligned with the standard’s requirements or if you’re missing key components as well as point to areas where improvements are needed. This is a time to be honest with yourself and to grade your programs critically.
To accomplish this, you can pose specific questions applicable to the sort of program you’re auditing. When auditing a hazardous waste operation, for example, the following questions are routinely addressed:
- Are all waste containers labeled?
- Are incompatible waste streams physically separated?
- Does the label communicate the hazard and the chemical components of the waste?
- Are all containers closed when not actively in use?
- Are there records of waste determination for each waste stream?
These questions are asked mainly because these violations are easy for an external auditor to spot. These are sometimes referred to as “low hanging fruit.”
If your assessment reveals that any of these requirements are not being met, the program should be identified as “Not in Compliance.” This indicates that a real audit will likely fail. Internal practice audits identify which required areas are lacking and require attention. Honing in on these weak spots can help set measurable future compliance goals with informed timelines for completion. Maintaining external audit readiness over time shows that your facility is taking EHS prioritization seriously and will go a long way to real-world compliance.