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EMS and Regulatory Compliance Internal Auditing. Bet Zimmerman, CEP, EMS-A PNNL, ESH&Q EFCOG Conference March 9, 2005. Outline. Why : Purpose and Requirement Who : Team Selection When : Planning & Scheduling How : Logistics, Tools, Approaches Reporting Delighting auditors

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ems and regulatory compliance internal auditing

EMS and Regulatory ComplianceInternal Auditing

Bet Zimmerman, CEP, EMS-A

PNNL, ESH&Q

EFCOG Conference March 9, 2005

outline
Outline
  • Why: Purpose and Requirement
  • Who: Team Selection
  • When: Planning & Scheduling
  • How:
    • Logistics, Tools, Approaches
    • Reporting
    • Delighting auditors
    • Keys to success
  • Questions

2

purpose of ems audit
Purpose of EMS Audit
  • Test whether system has been implemented and maintained
  • Should be a hard internal look
    • Gain real understanding of strengths and weaknesses
    • Goal is NOT to dupe auditors

3

requirement
Requirement
  • ISO 14001 requires procedure for periodic EMS audits
  • Auditors trained and competent – See ISO 19011
  • Auditors and process objective, impartial
  • If you don’t have ISO 14001 EMS, should still periodically evaluate system

4

team lead
Team Lead
  • Point of contact
  • Develop audit plan
  • Keep on schedule and on track
  • Summarize at end of each day, discuss categorization of findings
  • Prepare closing meeting presentation
  • Ensure report is delivered on schedule
    • Compile and finalize

5

team mix
Team Mix
  • ISO 14001 auditor training
  • Members: 1-3 max in addition to lead
  • Mix
    • One with environmental background
    • One with quality background
    • One from inside organization
  • Good interpersonal skills
  • Objective and inquisitive

6

shared resources
Shared Resources

ORNL

BNL

BCO

PNNL

Private Sector

7

planning
Planning
  • Allow time to correct problems before ISO 14001 registration audits
  • All 17 elements don’t have to be audited every year – should hit all in 3 year period
    • Frequency based on results of previous audits, environmental importance of activities
  • Selection criteria:
    • Not assessed in previous 2 years
    • Identified for follow-up/review during previous audit
    • Don’t have good handle on whether it’s working
    • Problem areas
    • New requirement being implemented
    • If engine isn’t working, don’t focus on the muffler

8

scheduling meetings

Out to Lunch

Scheduling Meetings
  • Schedule key interviews
    • Mix it up
  • Leave time
    • in between
    • for follow up
    • to review information
  • Schedule caucus
  • Schedule daily outbrief
  • Invite interviewees, ECRs/EMS Reps and key managers to opening and closing meetings

9

scheduling interviews
Scheduling Interviews
  • Develop e-schedule that shows
    • Daily
    • All auditors on one page
    • Time slots
    • Interviewee name, location, phone number, title, organization
    • Topics

10

use of checklist
Use of Checklist
  • Reminder of standard, prompts with questions
  • Divides up responsibility among auditors
  • Organizes information by element
  • Tips:
    • Use standard form, maintain online
    • Update to capture 14001:2004 requirements
    • With teams, use Sharepoint to complete
    • Appropriate level of detail
  • Track recommendations on what to cover in next audit

11

logistics
Logistics
  • Administrative point of contact
  • Meeting room
    • Access to Internet, phone, copier, printer, whiteboard
    • For daily debriefings
    • Place to leave materials

12

notification
Notification
  • Avoid “Who the #*%$ are you?”
  • What, why, when, how, where, who
    • Reason and Scope
    • Dates
    • Auditors
    • Who they are interacting with
    • Time, place and location of opening and closing meetings
    • Who to contact with questions

13

interviewing

OBJECTIVE EVIDENCE

Interviewing
  • Be on time
  • Introduce self, explain purpose
  • Ask to briefly describe responsibilities
  • Request objective evidence!
  • Make note of any documents requested
    • Obtain while onsite
  • Summarize at end to validate and provide preliminary feedback

14

comportment
Comportment

ISO RCRA P2EMS NCR SBMS R2A2QMS BLYPXK

15

reporting

Just the facts, ma’am

Reporting
  • Provide daily report on findings
  • Start writing up report during audit
  • Document findings – relative to element
    • “Actionable”
    • Clear
  • Separate recommendations from nonconformities
  • Avoid opinions
  • Executive summary
  • Allow 2 weeks for factual accuracy review and comment

16

closing meeting
Closing Meeting
  • No surprises at closeout!
  • Review findings
    • Nonconformities
    • Noteworthy practices and progress
    • Put in perspective
  • Review next steps
  • Review lessons learned
    • Ask for:
      • questions/reactions
      • input on how to further improve process

17

compliance assessment methods
Compliance Assessment Methods
  • Select several compliance areas:
    • Problem and not a problem – e.g., air compliance
    • Line and corporate-level
  • How are EMS elements implemented (or not) relative to that issue, e.g.:
    • Applicable legal requirements understood?
    • Goals established to address problems?
    • Practices consistent with documented operational control procedures?
    • Monitoring?
    • Adequate measures taken to prevent recurrence?

18

use of results
Use of results
  • Consider whether it’s an isolated incident or larger issue
  • Prioritize
  • Don’t chop heads off
  • Assign to real owner
  • Track to closure

19

on the receiving end delight auditors
On the Receiving End: Delight Auditors
  • Orientation
  • EMS manual with pointers
  • Computer access/hard copies
  • Scheduled interviewees prepared with materials, examples
  • Prompt and helpful follow-up
  • Okay to seek clarification/correction of findings

20

keys to success
Keys to Success
  • Plan well
  • Assemble competent team
  • Auditee cooperates
  • Report results in a meaningful way
  • USE results to improve

21