One of the initial steps that Cemtek likes to take is a site-specific compliance review, or gap analysis. (see Our Process) This step compares actual facility operations to permitted requirements, and highlights areas in need of attention. CAP can audit entire company portfolios using the same principles resulting in standardized practices across the organization.
The idea of your facility undergoing a compliance audit is not likely to evoke an enthusiastic response, but with the very real threat of enforcement action against your facility, including a regular audit into your compliance program, is sound business strategy.
An audit is a valuable tool in your compliance management tool box. Short-term compliance auditing costs are very low when looking at the bigger picture. (see Cautionary Tales at bottom of page).
The goal of an audit is to identify instances of non-compliance, learn their causes, and present a concise report to upper management. The results are then ideally used to structure a compliance plan. Audit findings usually hint toward logical future actions. For example, during an audit we may find improper labeling on a container, which though easily corrected, may highlight a lack of training that caused its misidentification in the first place.
In unique cases, regulatory specific audits can be conducted to aid management in planning compliance strategies. NSPS regulations are often included in such audits.
Understandably the prospect of hiring outside help may seem unnecessary when you have an environmental manager already on board, but remember, audits should be unbiased. An impartial evaluation is critical for a company to ensure it is meeting regulatory requirements in the most efficient way possible.
Our goal is to help our clients achieve their compliance obligations. Contact a Cemtek representative today to discuss how we help your company succeed.
DO’S AND DON’TS WHEN PLANNING FOR AN AUDIT
DO identify potential problems or a areas of concern (for planned audits).
DO define the objectives for the audit.
DO communicate with your staff. An audit can be unnerving, discussing the results, how the issues can be addressed and providing positive feedback will help your facility obtain it’s compliance objectives.
DO take action after the audit by creating plans and implementing the corrections needed to maintain or return to compliance.
DON’T conduct a pre-audit to fix issues. In doing so you remove an opportunity to discover the “root causes” of the issues.
DON’T “clean house” prior to your audit. Elimating routine regulated activity from the site prior to the audit defeats one of the purposes of the audit, to identify and review areas of concern.