Compliance audits are a tool commonly employed by EHS managers to evaluate the effectiveness of their programs in meeting national, regional, and local regulatory requirements. Comprehensive audits will present not only non-compliances, but also root causes and corrective actions. Based on internal capabilities and the reality of EHS budgets, companies can decide whether external consultants will play a role in executing audit programs.
When considering an audit program, the ideal solution for your business should:
- Be easy-to-implement, cost-effective, efficient, and adaptable to the varying needs of each part of the organization;
- Be supported by comprehensive and applicable audit protocols;
- Track and manage findings and corrective actions to closure; and
- Provide configurable reports on audit results.
Benefits of a solid program include being able to compare auditing results from multiple locations (even across different countries), managers getting a real-time view of audit results, the ability to control timing and predict costs accurately, and a repeatable and sustainable process. Compliance becomes part of your culture, and improvement from year to year and audit to audit becomes measurable. In short, better input gets you better output.
So how do you get there? With so many factors to consider, what approach works best for your organization? To help, Antea Group has developed a matrix of audit team concepts for use in determining the best approach for your audit program.
Your internal audit team does not include consultants—instead, subject matter experts with company‐ and regulatory-specific knowledge provide detailed audit coverage. Costs typically fall back to the facility or business unit EHS budget unless compensated by corporate.
Disadvantages include the absence of consultants who can bring industry experience from outside your firm (potentially from your peers) and the fact that you may bear the cost of training internal resources.
Hybrid, Internally Lead:
The hybrid audit structure includes both internal team members and external consultants and is led by an internal company audit leader. Advantages to this structure include high quality coverage of the audit topics by internal and external subject matter experts (SMEs), opportunities to obtain audit training experience for internal site‐level staff, and flexibility in selecting specialty auditor topic coverage (since consultants create a deeper auditor pool).
Disadvantages may include moderate commitment of internal resources (site level personnel hours and travel costs), a higher commitment of corporate EHS to having audit managers pulled off of other activities, moderate consultant costs, and some discontinuity in writing style in the delivery of the findings.
Hybrid, Externally Lead:
The consultant‐led hybrid audit structure includes both internal and consultant team members but is led by an external consultant audit leader. Advantages and disadvantages are similar to the internally led hybrid structure. The consultant‐led hybrid audit may be easier to implement in some cases, as it decreases the corporate time commitment to auditing.
The external auditor structure consists of a team solely made up of consultant auditors. A corporate representative may be present to serve as a facilitator/moderator to represent the audit program. Advantages include detailed coverage of the audit topics by SMEs that have experience from outside the company culture.
External costs for labor and travel, while highest of these options, is well‐defined prior to the audit. Because the corporate representative is the sole internal attendee, this audit structure risks the loss of company institutional knowledge (e.g., knowing "this is how we solved the issue at the other plant.").
By considering your corporate culture and time, money, and resource availability, you should be able to determine which approach might work best for your needs. Consider as well the geography of your facilities (are they spread across different states or countries, with different regulatory environments?) and the depth of knowledge and experience your internal team possesses. Any one of these approaches can produce great results—the critical step is making sure your approach matches your needs.