Former Defense Secretary Donald Rumsfeld once said:

There are known knowns. These are things we know that we know. There are known unknowns. That is to say, there are things that we know we don’t know. But there are also unknown unknowns. There are things we don’t know we don’t know.

So there are things that we know for sure, and there are things that we know we don’t know. And then we also have things that we don’t know that we don’t know.

The third category is what we want to uncover in an environmental audit.

When we ask the question “Why do you do it this way?” during an audit, we often get the answer: “We have always done it this way. We have been doing it this way for years.”

There are two possible interpretations of this answer. The first one is that they have been doing it correctly for years and there is no problem. The other interpretation is that they have been doing it incorrectly for years WITHOUT knowing it. In other words, they don’t know what they don’t know.

For example, a waste generator in California may know that his spent solvent is a hazardous waste. He may not know exactly how to manage that hazardous waste. That is not a big issue since he knows that he lacks that knowledge, and he will seek assistance. But does he know that if a drum of virgin solvent is mislabeled or shows signs of deterioration, that drum of virgin solvent becomes a waste after a short period of time in accordance with 22 CCR 66261.2(f)^[1]? Since the solvent is ignitable, that drum of virgin solvent will be classified as hazardous waste.

The owner of the drum of mislabelled virgin solvent is very likely someone who does not know what he does not know, and he will stay that way until either an auditor or inspector points it out to him.

So it is the job of an environmental auditor to identify areas of knowledge where the facility does not know what it does not know.

That is a very good reason to have periodic environmental audits.

About the Author

Norman Wei is the owner and principal instructor at Environmental Management and Training, LLC. in Cape Coral, Florida. He conducts seminars and webinars on environmental compliance. He can be reached at [email protected]

Photograph: Texture by Gabriella Fabbri

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^[1]22 CCR 66261.2(f) A material is a waste if it poses a threat to human health or the environment and meets either, or both, of the following:

(1) it is mislabeled or not adequately labeled, unless the material is correctly labeled or adequately labeled within 10 days after the material is discovered to be mislabeled or inadequately labeled;

(2) it is packaged in deteriorated or damaged containers, unless the material is contained in sound or undamaged containers within 96 hours after the containers are discovered to be deteriorated or damaged.