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	<title>Comments on: EHS Audits – Have We Lost Our Way? A Sequel</title>
	<atom:link href="http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%E2%80%93-have-we-lost-our-way-a-sequel/2011/feed/" rel="self" type="application/rss+xml" />
	<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/</link>
	<description>Practical Solutions for Environmental, Health &#38; Safety Professionals</description>
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		<title>By: EHS Audits – Have We Lost Our Way? Part III - EHS Journal</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-58037</link>
		<dc:creator>EHS Audits – Have We Lost Our Way? Part III - EHS Journal</dc:creator>
		<pubDate>Tue, 12 Mar 2013 19:48:51 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-58037</guid>
		<description><![CDATA[[...] titled “EHS Audits – Have We Lost Our Way?”  That article was followed a year later by a sequel that explored the topic more fully.  The articles elicited numerous thoughtful comments and much [...]]]></description>
		<content:encoded><![CDATA[<p>[...] titled “EHS Audits – Have We Lost Our Way?”  That article was followed a year later by a sequel that explored the topic more fully.  The articles elicited numerous thoughtful comments and much [...]</p>
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		<title>By: Classic Auditor Failures - EHS Journal</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-35851</link>
		<dc:creator>Classic Auditor Failures - EHS Journal</dc:creator>
		<pubDate>Sat, 30 Jun 2012 20:50:21 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-35851</guid>
		<description><![CDATA[[...] EHS Audits – Have We Lost Our Way? A Sequel (Cahill and Costello) [...]]]></description>
		<content:encoded><![CDATA[<p>[...] EHS Audits – Have We Lost Our Way? A Sequel (Cahill and Costello) [...]</p>
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		<title>By: Scott Belanger</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-29702</link>
		<dc:creator>Scott Belanger</dc:creator>
		<pubDate>Wed, 25 Apr 2012 13:45:54 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-29702</guid>
		<description><![CDATA[The value of any audit is really  based on two primary factors. 1) The skills of the audit team in identifying and effectively communicating risks 2) The action taken by the organization with the information provided.  This is really the ying and yang of the audit process.  If the audit is weak or reports only trivial issues, management is being misinformed as to the state of the business.  If managment fails to act of effectively delegate findings with effective contain, corrective and preventative action programs, then what is driving the audit team to raise the bar at the next audit?

The two factors need to continually challenge each other and be involved in both aspects of the process. Finding things wrong is easy, ask any consultant! Fixing things that are wrong so they can&#039;t go wrong ever again (fool proofing) is the opportunity that needs to be embraced by all parties. Management teams should never accept a weak audit (except maybe by a regulator!)  just as they won&#039;t accept substandard work from a supplier.  Audits if used properly should be able to add value to a business, if they are not then the audits are either weak or the managmeent team is keeping their head in the sand.

When I hear people say things like &quot;We need to eliminate all risks&quot; I like asking them how they plan on stopping people from sneezing while they drive to work.  We need to assess risks and manage them accordingly based on the businesses we are in and the level of risk that is acceptable to the management team.  

So on your next audit - do as Emerald Lagasse does &quot;kick it up a notch&quot;, put a little &quot;bam&quot; into it, dig a couple steps deeper, challenge the management team to identify and prevent the root cause from happenening again. Facilitate the entire audit process, not just the audit itself.  Show your company the value of your audits.]]></description>
		<content:encoded><![CDATA[<p>The value of any audit is really  based on two primary factors. 1) The skills of the audit team in identifying and effectively communicating risks 2) The action taken by the organization with the information provided.  This is really the ying and yang of the audit process.  If the audit is weak or reports only trivial issues, management is being misinformed as to the state of the business.  If managment fails to act of effectively delegate findings with effective contain, corrective and preventative action programs, then what is driving the audit team to raise the bar at the next audit?</p>
<p>The two factors need to continually challenge each other and be involved in both aspects of the process. Finding things wrong is easy, ask any consultant! Fixing things that are wrong so they can&#8217;t go wrong ever again (fool proofing) is the opportunity that needs to be embraced by all parties. Management teams should never accept a weak audit (except maybe by a regulator!)  just as they won&#8217;t accept substandard work from a supplier.  Audits if used properly should be able to add value to a business, if they are not then the audits are either weak or the managmeent team is keeping their head in the sand.</p>
<p>When I hear people say things like &#8220;We need to eliminate all risks&#8221; I like asking them how they plan on stopping people from sneezing while they drive to work.  We need to assess risks and manage them accordingly based on the businesses we are in and the level of risk that is acceptable to the management team.  </p>
<p>So on your next audit &#8211; do as Emerald Lagasse does &#8220;kick it up a notch&#8221;, put a little &#8220;bam&#8221; into it, dig a couple steps deeper, challenge the management team to identify and prevent the root cause from happenening again. Facilitate the entire audit process, not just the audit itself.  Show your company the value of your audits.</p>
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		<title>By: Repeat Versus Recurring Findings in EHS Audits - EHS Journal</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-27584</link>
		<dc:creator>Repeat Versus Recurring Findings in EHS Audits - EHS Journal</dc:creator>
		<pubDate>Sun, 01 Apr 2012 04:14:18 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-27584</guid>
		<description><![CDATA[[...] EHS Audits – Have We Lost Our Way? A Sequel (Cahill and Costello) [...]]]></description>
		<content:encoded><![CDATA[<p>[...] EHS Audits – Have We Lost Our Way? A Sequel (Cahill and Costello) [...]</p>
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		<title>By: Kevin A. Lehner, EMS-LA</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-13373</link>
		<dc:creator>Kevin A. Lehner, EMS-LA</dc:creator>
		<pubDate>Sun, 21 Aug 2011 15:33:03 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-13373</guid>
		<description><![CDATA[Thanks for the thoughtful article.  Is the role of determining the level of potential risk associated with both environmental aspects and health and safety hazards more appropriately placed in the domain of consultancy rather than that of the auditor?   If the work to identify EH&amp;S risks is done skillfully by the organization, and appropriate controls established to mange the EH&amp;S risk to tolerable levels, the role of the auditor is then to verify the effectiveness of the controls, not to determine the need for them.

The role of the auditor should be to understand the audit criteria, collect and review audit evidence against those criteria, make findings regarding conformity with the criteria based on the review of the evidence, and then draw audit conclusions about the effectiveness of the organizations management system to control the risks to a tolerable level.]]></description>
		<content:encoded><![CDATA[<p>Thanks for the thoughtful article.  Is the role of determining the level of potential risk associated with both environmental aspects and health and safety hazards more appropriately placed in the domain of consultancy rather than that of the auditor?   If the work to identify EH&#038;S risks is done skillfully by the organization, and appropriate controls established to mange the EH&#038;S risk to tolerable levels, the role of the auditor is then to verify the effectiveness of the controls, not to determine the need for them.</p>
<p>The role of the auditor should be to understand the audit criteria, collect and review audit evidence against those criteria, make findings regarding conformity with the criteria based on the review of the evidence, and then draw audit conclusions about the effectiveness of the organizations management system to control the risks to a tolerable level.</p>
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		<title>By: Lawrence Heim</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-13302</link>
		<dc:creator>Lawrence Heim</dc:creator>
		<pubDate>Sat, 20 Aug 2011 02:25:27 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-13302</guid>
		<description><![CDATA[Excellent points without doubt, but a couple thoughts.  The article defines &quot;risk&quot; in a somewhat circular manner, indicating that &quot;risk&quot; consists of two dimensions - &quot;consequences&quot; and &quot;risk&quot;.  In the traditional risk management (RM) world, &quot;risk&quot; is indeed generally viewed as having two components,  one component being a time element (frequency or likelihood) while the other reflecting a magnitude of effect (severity or impact).  Using the terms &quot;consequences&quot; and &quot;risk&quot; may not align with companies&#039; internal RM Departments, possibly making communications with them a little difficult or complicated.  

This is becoming increasingly important in my opinion as I am frequently asked to help clients adapt their own internal RM methods/frameworks to be used by internal EHS staff.  This also includes adapting risk assessment methods that are somewhat standardized for traditional risk management, such as Failure Mode Effect Analysis (FMEA) - a state of the art risk assessment process widely used in property risk assessment/insurance applications (and to a lesser extent in casualty risk).

Two fundamental aspects of EHS risk assessments that need to be addressed before launching such approaches are:
    - defining the parameters/benchmarks for &quot;severity&quot; and &quot;frequency&quot; - what does &quot;high&quot; and &quot;low&quot; mean?  What dollar values should be used?  What other indicators might also apply?
    - &quot;gross risk&quot; versus &quot;net risk&quot; - should the process quantify the risk profile assuming controls do not exist or will fail, thus indicating the worst case scenario?  Or should the output reflect the existence and effectiveness of controls that are in place?

Of course, risk maps are extremely helpful and intuitive graphical devices to show the results of the assessment, as the article clearly shows.  Typically, the first question posed is &quot;How do we move the risks from the outer edges to the lower left hand corner of the map?&quot;  Again, using a frequency/severity structure can be instructive in answering the question.  Consider a risk point that is high severity but low frequency (a Black Swan event like Fukushima).  There may be no practical way to reduce the frequency, therefore a solution aimed at frequency reduction will provide little value.  A more appropriate response is to reduce the severity of the event when (or if)  it occurs.  In this context, the more appropriate control may be a financial solution such as insurance.  Conversely, low severity events that happen frequently (like first aid cases) would be better addressed through a management system solution (such as training or making additional PPE available) rather than a financial solution.  

The integration of &quot;risk&quot; into EHS and sustainability is still a work in progress in our field.  As I have espoused for a number of years, EHS staff not define risk on their own - but do so using existing benchmarks, standards and definitions that have been validated many times over within internal RM departments.  EHS professionals should try to work with their company&#039;s RM staff to achieve this, or engage external support with significant first hand experience in EHS and traditional risk management.]]></description>
		<content:encoded><![CDATA[<p>Excellent points without doubt, but a couple thoughts.  The article defines &#8220;risk&#8221; in a somewhat circular manner, indicating that &#8220;risk&#8221; consists of two dimensions &#8211; &#8220;consequences&#8221; and &#8220;risk&#8221;.  In the traditional risk management (RM) world, &#8220;risk&#8221; is indeed generally viewed as having two components,  one component being a time element (frequency or likelihood) while the other reflecting a magnitude of effect (severity or impact).  Using the terms &#8220;consequences&#8221; and &#8220;risk&#8221; may not align with companies&#8217; internal RM Departments, possibly making communications with them a little difficult or complicated.  </p>
<p>This is becoming increasingly important in my opinion as I am frequently asked to help clients adapt their own internal RM methods/frameworks to be used by internal EHS staff.  This also includes adapting risk assessment methods that are somewhat standardized for traditional risk management, such as Failure Mode Effect Analysis (FMEA) &#8211; a state of the art risk assessment process widely used in property risk assessment/insurance applications (and to a lesser extent in casualty risk).</p>
<p>Two fundamental aspects of EHS risk assessments that need to be addressed before launching such approaches are:<br />
    &#8211; defining the parameters/benchmarks for &#8220;severity&#8221; and &#8220;frequency&#8221; &#8211; what does &#8220;high&#8221; and &#8220;low&#8221; mean?  What dollar values should be used?  What other indicators might also apply?<br />
    &#8211; &#8220;gross risk&#8221; versus &#8220;net risk&#8221; &#8211; should the process quantify the risk profile assuming controls do not exist or will fail, thus indicating the worst case scenario?  Or should the output reflect the existence and effectiveness of controls that are in place?</p>
<p>Of course, risk maps are extremely helpful and intuitive graphical devices to show the results of the assessment, as the article clearly shows.  Typically, the first question posed is &#8220;How do we move the risks from the outer edges to the lower left hand corner of the map?&#8221;  Again, using a frequency/severity structure can be instructive in answering the question.  Consider a risk point that is high severity but low frequency (a Black Swan event like Fukushima).  There may be no practical way to reduce the frequency, therefore a solution aimed at frequency reduction will provide little value.  A more appropriate response is to reduce the severity of the event when (or if)  it occurs.  In this context, the more appropriate control may be a financial solution such as insurance.  Conversely, low severity events that happen frequently (like first aid cases) would be better addressed through a management system solution (such as training or making additional PPE available) rather than a financial solution.  </p>
<p>The integration of &#8220;risk&#8221; into EHS and sustainability is still a work in progress in our field.  As I have espoused for a number of years, EHS staff not define risk on their own &#8211; but do so using existing benchmarks, standards and definitions that have been validated many times over within internal RM departments.  EHS professionals should try to work with their company&#8217;s RM staff to achieve this, or engage external support with significant first hand experience in EHS and traditional risk management.</p>
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		<title>By: Laura McHugh</title>
		<link>http://ehsjournal.org/http:/ehsjournal.org/lawrence-cahill-robert-costello/ehs-audits-%e2%80%93-have-we-lost-our-way-a-sequel/2011/comment-page-1/#comment-13199</link>
		<dc:creator>Laura McHugh</dc:creator>
		<pubDate>Wed, 17 Aug 2011 14:40:49 +0000</pubDate>
		<guid isPermaLink="false">http://ehsjournal.org/?p=3421#comment-13199</guid>
		<description><![CDATA[As auditors, we need to help our audited organizations understand the value of performing meaningful root-cause analyses and risk maps like those presented in this article. Audits should be part of an organization&#039;s compliance management system, the &quot;check&quot; in the Plan-Do-Check-Act process of continual improvement toward identification and mitigation of organizational risks from E and HS risks.

Great articles! Thanks for publishing.]]></description>
		<content:encoded><![CDATA[<p>As auditors, we need to help our audited organizations understand the value of performing meaningful root-cause analyses and risk maps like those presented in this article. Audits should be part of an organization&#8217;s compliance management system, the &#8220;check&#8221; in the Plan-Do-Check-Act process of continual improvement toward identification and mitigation of organizational risks from E and HS risks.</p>
<p>Great articles! Thanks for publishing.</p>
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