Audits are an important business tool for assessing liabilities and risks, satisfying requirements from regulators, and providing greater transparency to customers. For companies engaged in activities that fall under a regulatory agency, Environmental Standards, Inc.’s auditors provide technical support and focused guidance based on over 30 years of industry experience.
Our team consists of experienced auditors, who not only know the regulatory rules but have also implemented and assessed compliance against them. Our auditors can help you at the strategic level by maximizing competitive advantages from regulation, through the operational level by minimizing costs and disruptions to your business, freeing up management time in the process.
Environmental Standards offers auditing services which encompass multiple industries and functions.
- Process Safety Management (PSM) and Risk Management Plan (RMP) audits
- Environmental compliance facility audits
- Transportation and logistics audits
- Leak detection and repair (LDAR) audits
- Waste vendor audits
- External laboratory audits
- Internal laboratory audits
- Field sampling audits
Process Safety Management and Risk Management Plan Audits
Environmental Standards’ conducts process safety management (PSM) risk management plan (RMP) audits in accord with OSHA and US EPA regulations using highly experienced auditors/practitioners, many of whom are subject matter experts. We can supply lead auditors, audit team members, or full audit teams.
Our PSM audit teams include certified auditors (e.g., CPEA, CPSA, CQA), professional engineers (PE), certified safety professionals (CSP), and certified hazardous material managers (CHMM). Combining the disciplines of engineering, chemistry, and safety with the experiences gained by years of company and/or facility management yields highly effective and value adding audits for our clients.
Our teams have conducted PSM/RMP audits nationally and internationally for a variety of industries – oil & gas, industrial/manufacturing, food and beverage, transportation/railroad, etc. Whether leading an audit, joining an audit as a team member, or supplying a complete audit team, Environmental Standards works with clients across many industries and markets to conduct audits tailored to their specific needs and requirements.
- Comprehensive PSM/RMP audit program development
- Independent third party review of existing PSM/RMP audit program including program and applicability determination and review.
- Employee participation; Operating procedures; Training; Contractors; Hot work; Incident investigation; Process hazard analysis (PHA); Pre-startup safety reviews (PSSR); Mechanical integrity; Process safety information (PSI); Management of change (MOC); Emergency planning and response; and state/county-specific requirements.
- Identify opportunities for continuous improvement
- Identify gaps in Audit Program implementation
Environmental Compliance Facility Audits
Environmental compliance is an essential and unavoidable step of responsible environmental program management. Compliance, as a corporate or organizational goal, cannot be avoided or minimized. Environmental compliance audits are an important tool in ensuring compliance to meet the requirements of federal (US EPA, DOT, and OSHA), state (DEP/DEQ), and local regulations stipulated in 40 CFR, 49 CFR, and 29 CFR. Additionally, maintaining environmental compliance is considered the minimum standard of care for responsible corporate or facility environmental management.
On behalf of industrial clients, law firms, insurance companies Environmental Standards provides a full range of environmental regulatory compliance audits, including:
- Resource Conservation Recovery Act (RCRA)
- Solid and Hazardous Waste Management (CESQG, SQG, LQG, and TSDF)
- Universal Waste Management (SQUWH, LQUWH)
- Electronic Waste (E-Waste)
- Hazardous material and CERCLA hazardous substance management
- Emergency Planning and Community Right to Know Act (EPCRA)
- Superfund Amendments and Reauthorization Act (SARA) Reporting
- Tier II and TRI reporting
- Clean Air Act (CAA)
- Title I, III, IV, V permit implementation
- NSR, NSPS, and NESHAP review and applicability determination
- Protection of Stratospheric Ozone (ODS, Freon recovery)
- Air permits under local jurisdiction
- Underground Storage Tank (UST) and Above-Ground Storage Tank (AST)
- Used oil
- CERCLA Hazardous Waste
- State and Local regulations and applicability determination
- Inspections and labeling
- Air emissions from hazardous waste/substance tanks
- Toxic Substance Control Act (TSCA)
- Polychlorinated Biphenyl (PCB) management
- Radon, Asbestos, and Lead-based Paint issues
- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
- Clean Water Act (CWA)
- Spill Prevention, Control, and Countermeasure Plan (SPCC)
- National Pollution Discharge Elimination System (NPDES) Permits and Storm Water Pollution Prevention Plans (SWPPP)
- MS4 Systems
- Sewer Use Discharge Permits to Publicly Owned Treatment Works (POTW)
- Safe Drinking Water Act (SDWA)
- Hazardous Material Storage and Transport
- Department of Transportation (DOT) Compliance
- Fire Code placarding
- GHS and Hazcomm Compliance
Transportation and Logistics Audits
Environmental Standards’ provides program- and procedure-level auditing and quality assurance support for a variety of transportation and logistics activities – whether transporting petroleum products or hazardous materials by truck, rail, pipeline, or vessel.
Waste Vendor Audits
As established under the Resource Conversation and Recovery Act (RCRA), a company’s liability for hazardous waste does not end when the waste is hauled away by a waste vendor (i.e., construction and removal contractors, waste haulers/transporters, waste transfer facilities, and facilities engaged in the Treatment Storage or Disposal [TSDF] of waste). Auditing waste vendors as part of a Waste Vendor Management Program is an effective way to manage and reduce that liability and risk. In conjunction with procurement efforts, auditing serves as an important mechanism to gather information to ensure consistency in waste vendor selection, criteria, and performance. Audits may be performed remotely (i.e., desktop audits) or on-site. On-site audits are most appropriate when a company is exposed to high risk (e.g., large volume of waste being shipped to a specific site) or if practical considerations provide a strong economic incentive to use the site, but little or no information is available to gauge vendor performance.
Environmental Standards employs seasoned auditing professionals including certified auditors (e.g., CPEA, CPSA, CQA), professional engineers (PE), certified safety professionals (CSP), and certified hazardous material managers (CHMM). Our audit team has performed numerous waste vendor audits across the US, auditing a wide range of waste vendors and their operations:
- Transporters and DOT regulations
- Oil and Gas Waste (including Injection Wells and other TSDF)
- Landfills and land farms
- Treatment facilities (waste piles, incinerators, thermal treatment and chemical, biological and physical treatment, etc).
- Storage facilities (compatible containers, accumulation limits, highly flammable wastes, etc.)
- TE-NORM and NORM from Oil and Gas drilling and transmission operations
External and Internal Laboratory Audits
Laboratory audits are an important tool for assessing liabilities that may arise from using a commercial laboratory. Environmental Standards’ dedicated Quality Assurance Chemists have performed hundreds of analytical laboratory audits nationwide at the request of industry, law firms, engineering firms, and even the laboratories themselves to enable them to meet their internal QA/QC requirements. Our laboratory audits are extremely rigorous and significantly exceed regulatory-based and ISO Standard 17025 requirements.
- Benzene Waste Operations NESHAP Laboratory Audits
- BWON Laboratory Audits
- Whole Effluent Toxicity (WET) Laboratory Audits
- Radioactive Material Laboratory Audits
- Dioxin/Furan Laboratory Audits
- Microbiology Laboratory Audits
Environmental Standards has conducted on-site third-party audits of hundreds of domestic (including facilities in Alaska, Hawaii, and Puerto Rico) and international laboratories (including facilities in Argentina, Australia, Belgium, Canada, France, Germany, Hungary, Mexico, Norway, South Korea, and United Kingdom). International audits require a high-level of expertise to evaluate good analytical practices effectively because many foreign countries do not standardize regulatory methods.
Field Sampling Audits
A field sampling audit is an independent, non-biased review of the sampling and monitoring procedures being conducted in comparison to the project requirements. The primary goals of a field audit are to identify non-conforming items that have the potential to negatively affect data quality, institute corrective actions, and promote continuous program improvement. Field auditing is a valuable practice that is often viewed as a critical first step in the data defensibility process because an improperly collected sample will likely result in poor data quality. Likewise, inadequate pre-event planning will usually lead to a less than adequate sampling event. Field auditing is an effective tool used to identify and correct planning, sampling, and documentation deficiencies before they become consequential.
Following a field audit, a debriefing is conducted and a formal report or project memorandum is generated by Environmental Standards. The debriefing typically includes the client and the audited party and is used to document the sampling event, observations, positive feedback, and findings identified during the audit, and recommendations regarding process improvements and corrective actions.
A non-biased review of field procedures conducted during site investigation and sampling programs helps identify quality deficiencies prior to generating environmental data for risk-management decisions. Field auditing of sample collection procedures is effective in implementing real-time corrective action measures, and as such, is an integral step in ensuring quality data in a project life cycle. Our auditors have experience in identifying data collection, sample procurement, record-keeping, and health & safety issues before they become problematic. Audit results can be used to evaluate contractor performance, to document compliance with regulatory requirements, and as “lessons learned.”
For more information or to speak with an auditing professional, please contact Senior Advisor Michael R. Green, Ph.D., MBA, CPEA.