Two of the most critical factors in EHS auditing are competence and independence of the auditors. Most corporate internal audit departments are staffed by accountants who have very little knowledge of environmental issues and regulations. The worst thing a company can do is to hand a checklist to these internal auditors (accountants) and ask them to do an EHS audit while they are doing financial audits. I have seen that happen at a Fortune 500 company and it was a total disaster. Not only did the incompetent auditor fail to understand the basics of environmental issues, he also produced a misleading paper trail. Luckily I was able to alert the corporate law department in time to kill the report and make sure it never saw the light of day. On independence of the EHS auditor: It is a mistake to base EHS auditors in Operations because of the inherent conflict of interests. EPA's audit policy requires independence of the auditor and I am not sure this arrangement would satisfy that. In my opinion, the law department is the logical place for EHS auditors. It also offers an added level of attorney/client privilege protection for the report. What do you think?