Environmental, health, and safety (EHS) audits are supposed to be a collaborative activity in which independent auditors team up with facility personnel to conduct an objective review of the facility’s programs and procedures. Things usually go as planned, but if you encounter any of the following warning signs, your auditor’s radar should be sounding, “ DANGER… DANGER….”

1. No one is working. People scamper when they see the audit team.
2. There is no production in the unit you are auditing.
3. All inspection records are written the exact same way.
4. Records are locked in a file cabinet, and no one has the key.
5. All of the personal protective equipment (PPE) is new.
6. Employees are wearing PPE incorrectly.
7. The facility has planned lots of extracurricular activities for the audit team after hours.
8. The site plans to have lunch outside the facility every day.
9. Subject matter experts are not available.
10. A conference room is not available for the audit team, or the conference room doesn’t have an Internet connection.
11. The site manager doesn’t attend the opening or closing meetings.
12. You see new paint, new signs, or new paving.
13. No waste is present in the waste accumulation area, or facility personnel report that they don’t generate any waste.
14. There is significant turnover in the EHS or security manager role.
15. There are significant changes in spending on EHS projects. Is the facility spending more or less than in previous years?
16. First aid cases are unusually low for a facility in this industry.
17. Facility personnel are more concerned about the number of audit findings than the nature of the audit findings.
18. There is a strong emphasis on achieving awards. In this case, the bonuses of facility management may be tied to awards and performance.
19. Each department or division has a separate way of keeping records, defining compliance, providing training, managing risks, or conducting incident investigations.
20. People being interviewed suddenly cannot speak English or tell you they have to get their supervisor. Many times, these people never return.

If you encounter any of these warning signs, the facility may be trying to manage the audit process to limit the information that you receive, documents you review, and areas you inspect. In these cases, you’ll need to be courteous but tenacious. Dig deeper than you normally would, make sure that you’re getting to the bottom of each issue, and don’t assume that the first answer to your question is a complete and accurate response. No matter how many EHS awards the site has won or how many stories you hear about the facility’s EHS accomplishments, you need to be wary if you encounter any of these situations.

About the Author

Bill Qualls is a Certified Professional Environmental Auditor with more than 25 years of EHS auditing experience. He works in the chemical industry and is a member of the board of directors of the Auditing Roundtable.

Photograph: Puzzle by Nick Benjaminsz, Breda, Brabant, Netherlands.

Return to the EHS Journal Home Page