Monthly Archives: November 2011

Auditing roundtable meeting in Phoenix AZ – January 2012

I will be speaking at the Auditing Roundtable Annual Meeting in Phoenix Arizona on January 9 and 10, 2012.

On January 9 at 1:30 pm , I will be on a panel discussion on the topic “auditor’s conundrum” – what should an auditor do when he finds out his client is doing something that is causing imminent harm to the general public.

At 4 pm on January 10, I will be leading a discussion on the difference between compliance audit and management audit.

We do environmental audits for companies. Visit our website for details.

Sometimes…less is better

One of the attorneys I met on LinkedIn posted this little story. I am reproducing it here as a great teachable moment.

During the French revolution three prominent, but very unfortunate, professionals were condemned to beheading by the guillotine: a priest, a doctor, and an engineer. The three were conveyed to the scaffold together in an old ox cart and were marched up to the guillotine together amidst amass of cheering blood thirsty spectators. The priest was the first to meet his fate. The executioner very politely asked the priest if he preferred to avoid seeing the blade fall by lying face down rather than face up. The priest replied, “I’ve led a good life, have nothing to regret, and want to meet my maker face-to-face.” So the priest lied down facing the blade. The executioner pulled the cord releasing the blade and it plummeted toward the priest’s exposed neck. But within a half inch of reaching its fatal destination the blade stopped literally in its tracks. The crowd roared with delight and many of the onlookers fell to their knees in prayer. Not wanting to put any victim to double jeopardy the authorities released the priest, to the great delight of the crowd. Then came the doctor’s turn. He was asked the same question and thought “if it worked for the priest maybe it will work for me too,” so he requested to take the blade face up. Again the blade stopped a half inch from the target, and as with the priest, the authorities released the doctor. Now was the engineer’s turn and, being no one’s fool, he also opted to take the blade face up. As he lay with his neck firmly placed in the crook of the guillotine and looked up to his maker, and to the blade, he exclaimed, “Ooh, I think I see your problem.”

Moral of the story: Only answer the question that’s asked, and don’t volunteer information, your neck may be at stake, and in the case of this discussion, your client’s neck!

Remember this story next time when you are being deposed or when you are speaking with an inspector.

The concept of Generator’s Knowledge

There are two ways to determine if you have a hazardous waste: The first way is generator’s knowledge and the second way is laboratory analysis.

If you purchase and use 100 gallons of solvents a month to clean your machine, you know that you have generated spent solvent which in most instances is a hazardous waste. This is your “generator’s knowledge”. You do NOT need to analyze your spent solvent to show that it is hazardous. Based on your knowledge of how you use your material, you have the knowledge to determine that it is hazardous.


On the other hand, if you find 5 drums of unknown chemicals sitting in your warehouse and no one can tell you where they came from. You have NO generator’s knowledge and you must conduct chemical analysis to determine if these drums contain hazardous waste.