The best way to find out if you or anyone has an EMS is to do an “environmental management audit”. This is different from the conventional compliance audit where you ask the question: “Is anything wrong here TODAY?” That’s all you can hope for in a compliance audit. You are trying to find out if the facility is in compliance on the day you perform the audit. It is just a snap shot of the compliance status of the facility. It tells you nothing about what the status will be the next day or next year.
When you do an “environmental management audit”, you are asking this question: “What will they do when something goes wrong tomorrow?” You look at people. You observe how they react to environmental problems. You look at the procedures that they have put in place to plan for emergencies. You ask open-ened questions. You find out how they interact with agencies. All of these questions will help you determine if they have an effective environmental management system.