Feeling your way through an environmental audit

Good practice is sometimes overlooked – the busy auditor with experience often works by feel rather than following checklists and ISO standard requirements. Confidentiality issues prevents disclosure of details, but hopefully this blog illustrates a couple of points about how feel can add to good auditing technique during an environmental audit.

In this example, the site was well familiar to me. The processing facility was only a few years old and was extremely well maintained. It was operated by only one manager with one person as an operator. This small site received industrial gas from another plant through a pipeline, processed and refined it and then stored ready for collection by road tanker.

One simple technique is to ask about any incidents that have taken place in the last 6 months. A check of the register probably provides the details and the auditor can check for corrective, preventive action. It is a usual auditor process and one which takes the auditor straight into the core of the management system. Are issues that have been identified or submitted as complaints been addressed?  Of course, the auditor should tour the site and make note of anything that could indicate a problem – a stained concrete floor, a damaged piece of equipment. Auditors are looking for incidents that have NOT been included on the database as that would be a nonconformance.

In this case all was OK but an interesting observation related to a container half full of hypochlorite together with a thin plastic feed pipe. It turned out that the existing tank sprung a leak and had to be closed off – hence the presence of the new storage and feed arrangement. Knowing that a Management of Change process applied to all changes associated with processing equipment led to the question – did this follow the MoC process? The answer was “no” and so led to a nonconformity.

Another example related to a second site that processed gas to create a solid block type of product used within the food industry. A new processing line had been introduced 9 months earlier. The is a requirement that all changes are assessed from an environmental and H&S perspective (preferably before the equipment is used). In this case a closed question was asked  “Is there a risk assessment and does the aspect register record this change”. Because the answer was “no” then a nonconformity was written.

There was immediate agreement by the client regarding the findings which were classed as “minor”. The company then must implement changes and update relevant registers, otherwise the findings turn to “Major”. I always believe that a finding should be readily accepted by the client for it to work. The skill of the auditor is to reveal findings that are highly relevant, clear and which benefit the organisation. In this case both findings were exactly that!

Experience and skill combine to enable the auditor to feel for those meaningful findings during an audit.

Best Regards, John Marsden – 21^st February 2017