Why many internal environmental auditors go wrong

Some environmental managers get into a routine of doing environmental audit every year as part of their company policy. They develop a checklists and require the audit team members to follow the lists and never deviate from them. The checklists define the scope of the audit. Their efforts are more focused on documentation than discovery.

One auditor even went so far as to staiStock_000002888302XSmallte in LinkedIn that “you don’t conduct an audit to “fix” something, but rather as part of your quality/risk management policy.” So he was just going the motion to “fulfill” some nebulous risk management policy.

Somehow they have lost sight of the real reason people do environmental audits.

The fundamental reason and basis for doing routine audits is to uncover things that are wrong and fix them BEFORE they become unmanageable and/or too costly to fix. It is just like doing your annual physical examination. You want to see if there are any emerging medical problems that you can take care of before they become deadly. You absolutely do audit for the expressed purpose of identifying problems and fixing them. Otherwise you are just going through the motion. People should do auditing as part of their continuous improvement program. The word “improvement” means correcting things, fixing things and making things better. In fact, one of the continuous improvement steps is corrective actions. An annual medical check up is like your compliance audit. You look for problems and FIX them before they kill you. When your doctor sits down and discusses with you your life style (how much you drink and how often you smoke, etc), he is doing a management audit on you. And if your doctor has to refer to a checklist, get another doctor.
Checklists are only good for compliance audits – and marginally so. They tell you your compliance status at the time you perform your audit. The only thing they provide is a snap shot of compliance status and nothing more. If an auditor is any good at all, he should not have to rely on a list of things to tell him or remind him what to do. If you are doing management audit, you definitely do not want a checklist. But if you need a checklist to tell you what to look for, then you should not be doing management audit.

Be very wary of venders out there who try to sell you audit programs that consists of nothing but a bunch of canned checklists. If you feel you have to use a checklist, you need to take the time to develop or customize your own checklist. No two facilities are the same. 

Many auditors look for “consistent” audits. They want to see consistency year after year. Yet, a good audit is never consistent. At a recent conference of auditors, many environmental managers said they wanted the same old external auditors to do their audits every year in order to get “consistent” results. They didn’t want to spend time explaining their manufacturing process to a fresh face. They wanted someone who is very familiar with their operation.

These managers obviously have never heard of the term “familiarity breeds contempt”. They are in effect just going through the motion of getting their annual audit done because their corporate policy requires it. They are not interested in having a new auditor with a fresh set of eyes to find ways to improve their process or fix any problems that had been overlooked before. They might as well just photocopy the previous year’s report and save themselves some money.

One of the many reasons auditors (mostly inexperienced ones) like checklists is that they provide a scoring mechanism in addition to helping them remember what they ought to know in the first place. They run through a list of 100 items on the list and 80 are checked off. The facility gets a 80% score. And that’s better than the 75% score they got the year before. So there is reason for them to go out and celebrate. It is for this reason that many facilities view an audit as an examination that they need to pass. How often have we heard our clients say this “Whew..we passed another audit” as if it was an freshman examination? They see the audit report as a report card. The problem with such reasoning is that it takes the focus away from FIXING problems. Where is the incentive to fix problems if you “score” 80%? And what specifically are those missing 20%? What if the missing 20% include some serious environmental issues?
And that’s the main reason why so many audit reports sit on manager’s book shelf collecting dust. It is the erroneous misconception that audit is not about fixing problems. They forget all about it after they have passed “the test”. There are numerous major environmental disasters that occurred because management ignored previous audit findings and allowed (knowingly or unknowingly) the manageable problems to fester into a major problem. One of the largest sugar mills in the U.S. was decimated as a result of combustion of fine sugar dust. An internal audit had identified the underlying problems. One of them was a malfunctioning dust collection system. No one took any action to correct it adn the plant blew up.

Sometimes we get into the bad habit of testing just for the purpose of testing. The focus should always be on fixing the problem.

The completion of an audit is not the end. It is just the beginning.

The problem with setting audit protocol is that it places unnecessary restrictions on other auditors. Strict protocol tells the auditors to look for things that you want them to look for. It places blinders on the auditors unnecessarily. That’s where the excuse “it is not on my checklist or protocol” comes up most often. There should be broad outline and objective for the audit so that when an auditor walks past a badly corroded water tank next to a power substation on his way to complete the checklist elsewhere, he will have the good sense and “freedom” to include that in his report even though water tank is not on his checklist or protocol. Because when the tank collapses and takes out the substation and the plant is out of commission for a week, there will be hell to pay and senior management will not buy the “it is not on my checklist” excuse.

Author’s note: this is an except from an upcoming book “Practical Guide for Environmental Managers” by Norman Wei who has taught over 2000 corporate environmental managers on how to comply with enviornmental regulations.

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