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List of Figures and Exhibits | xx | |
Preface | xxiii | |
About the Editor and Principal Author | xxv | |
Contributing Authors | xxvii | |
Acknowledgments | xxxi | |
Part I | Managing a Program | |
Chapter 1 | Perspectives in EH&S Auditing | 3 |
Why Audit? | 3 | |
Impact on the Regulated Community | 11 | |
Evolution of Environmental Auditing | 16 | |
EH&S Auditing Organizations | 17 | |
Defining Environmental Audits | 18 | |
Advantages and Disadvantages | 20 | |
Trends in EH&S Auditing | 21 | |
Chapter 2 | Government Perspective | 25 |
Introduction | 25 | |
U.S. EPA Policy Encourages Use of Environmental Auditing | 27 | |
U.S. EPA's 1986 Auditing Policy and Elements of Effective Audit Programs | 28 | |
U.S. EPA's Audit Policy | 30 | |
Conclusions | 44 | |
OSHA's 2000 Self-Audit Policy | 44 | |
Chapter 3 | Legal Considerations | 47 |
Introduction | 47 | |
Function of Environmental Assessments | 48 | |
Role of Environmental Assessments | 49 | |
Federal Policies Encouraging Environmental Assessments | 50 | |
Protection Of The Confidentiality Of Environmental Assessments Under Existing Law | 55 | |
State Environmental Audit Legislation and Policy | 60 | |
Practical Considerations and Recommendations For Performing Self-assessments | 61 | |
Chapter 4 | Elements of a Successful Program | 65 |
Principles of an Audit Program | 65 | |
Planning the Program | 66 | |
A Key Program Issue: Corporate Standards and Guidelines | 84 | |
Additional Sampling | 87 | |
Continuous Review | 87 | |
Evaluating the Results and Implementing the Solutions | 88 | |
Chapter 5 | Impact of International Standards on EH&S Audit Programs | 89 |
The Key Initiatives | 91 | |
Corporate Responses | 102 | |
Conclusion | 108 | |
Chapter 6 | The Challenges of Meeting ISO 14000 Auditing Guidelines: Audit Program Gaps | 109 |
A Process to Evaluate the Adequacy of Resources | 110 | |
A Process to Evaluate Auditee Cooperation | 111 | |
A List of Auditees in the Audit Report | 112 | |
Identification of "Obstacles Encountered" in the Audit Report | 113 | |
Documentation of "Findings of Conformity" | 115 | |
An Appropriate Code of Ethics | 115 | |
A Non-Disclosure or Records Retention Policy | 116 | |
A Formal Audit Plan | 117 | |
Auditor Independence | 118 | |
Sufficient Program Guidance Documentation | 118 | |
Chapter 7 | A Review of Some Typical Programs | 119 |
Program Overview and Scope | 120 | |
Program Methodology | 123 | |
Program Operations | 126 | |
Conclusion | 127 | |
Chapter 8 | Benchmarking EH&S Audit Programs: Best Practices and Biggest Challenges | 129 |
Overview of Benchmarking | 130 | |
Best Practices | 133 | |
Biggest Challenges | 139 | |
Chapter 9 | Environmental Auditor Qualifications: Great Expectations | 143 |
Core Skills | 144 | |
Observations in the Field | 146 | |
Making Good Things Happen | 148 | |
Conclusion | 148 | |
Chapter 10 | Training EH&S Auditors | 149 |
The Need | 149 | |
Selecting the Trainers | 150 | |
Selecting the Trainees | 151 | |
Selecting the Setting | 151 | |
Selecting the Techniques | 152 | |
Chapter 11 | EH&S Audit Training in the Asia Pacific | 155 |
First Stop: Singapore | 156 | |
The Transition: Singapore to Japan | 159 | |
Second Stop: Japan | 159 | |
Chapter 12 | Information Management | 163 |
Regulatory Databases | 164 | |
Automated Checklists | 165 | |
Evaluating Auditing Software Systems | 168 | |
Chapter 13 | Using Groupware to Manage the EH&S Audit Program Documentation Process | 171 |
Importance of Sound Information Management | 171 | |
Traditional Responses to Audit Document Management | 172 | |
The Groupware Solution | 174 | |
Conclusion | 177 | |
Chapter 14 | Managing and Critiquing an Audit Program | 179 |
Beginning a Program | 179 | |
Managing a Program | 184 | |
Conclusion | 189 | |
Part II | Conducting the Audit | |
Chapter 15 | Conducting the EH&S Audit | 193 |
Introduction | 193 | |
Pre-audit Activities | 194 | |
On-Site Activities | 205 | |
Chapter 16 | Typical Compliance Problems Found During Audits | 223 |
EH&S Audits: What Can Go Wrong? | 223 | |
Common Compliance Problems | 224 | |
Typical Inspection Areas | 231 | |
Auditor's Reminder Checklist | 262 | |
Chapter 17 | Conducting Effective Opening and Closing Conferences | 267 |
Opening Conferences | 268 | |
Closing Conferences | 272 | |
Chapter 18 | Auditing Dilemmas | 279 |
The Management Systems Defense | 279 | |
The De Minimis Issue | 280 | |
Virtual Compliance | 281 | |
Unobtainable Verification | 281 | |
Non-Specific Corporate Standards | 281 | |
Conflicts Between Country Regulations and Corporate Standards | 282 | |
Repeat Findings | 283 | |
Just-in-Time Compliance | 283 | |
Regulatory Intent | 284 | |
Vague Regulatory Definitions | 284 | |
Chapter 19 | Preparing Quality EH&S Audit Reports | 287 |
Field Preparation | 288 | |
Report Preparation | 290 | |
Report Follow-Up | 301 | |
Chapter 20 | Environmental Auditing: A Modern Fable | 305 |
The Company | 305 | |
The Audit | 306 | |
The Beginning | 307 | |
The First Meeting | 307 | |
The Field Work | 308 | |
That Night | 309 | |
The Next Day | 310 | |
Finishing | 311 | |
The Briefing | 311 | |
The Report | 313 | |
Epilogue | 317 | |
Chapter 21 | Achieving Quality Environmental Audits: Twenty Tips For Success | 319 |
Do Not Ignore or Underestimate the Need to Prepare for and Plan the Audit and Its Logistics | 319 | |
Develop and Maintain a "Living" Agenda throughout the Audit | 320 | |
You Will Never Finish So Manage Your Time Wisely | 320 | |
Keep a Balance between Records Review, Interviews, and Observation | 321 | |
"Things" Will Happen on the Audit. Be Flexible | 322 | |
Always Be On Time Even When the Site Staff Are Not | 322 | |
Remember Site Staff Will Always Consider Audits a Performance Evaluation | 323 | |
In Spite of the Existence of Governmental Regulations and Company Standards, Considerable Judgment Is Still Required | 323 | |
Every Country, State, or Region Is Different | 323 | |
Learn and Apply the Audit Protocols, but Don't Forget to Use Your Common Sense and Natural Curiosity | 324 | |
Try to Observe Things as They Happen | 324 | |
Observe Ancillary Operations | 325 | |
Observe, Articulate, and Write, in That Order | 326 | |
True and Complete Root-Cause Analysis Can Be Complex, Difficult, and Time Consuming | 326 | |
Writing Is the Hardest Part; Developing "Bullet-Proof" Findings Is an Elusive Goal | 327 | |
Write the Findings as You Go | 327 | |
Prepare Well for the Opening and Closing Conferences | 328 | |
Make Sure the Site Hears the Real Story in the Closing Conference | 328 | |
Plan to Be Done When You Depart | 328 | |
Enjoy Yourself!!! | 328 | |
Part III | Special Auditing Topics | |
Chapter 22 | Property Transfer Assessments | 331 |
Introduction | 331 | |
Approach Overview | 334 | |
Scope and the ASTM Standard | 334 | |
Assessment Team | 334 | |
External Contacts | 335 | |
The Three Phases | 336 | |
Phase I337 | ||
Phase II344 | ||
Phase III344 | ||
Assessment Issues | 345 | |
Conclusion | 353 | |
Chapter 23 | Top Ten Reasons Why Phase I Environmental Assessment Reports Miss the Mark | 355 |
Failure To Maintain Independence and Objectivity | 357 | |
Failure To Define The Exact Scope of Work | 358 | |
Use of Conjecture in Report Findings | 359 | |
Use of Imprecise Language | 359 | |
Failure to Distinguish "Compliance" Findings From "Liability" Findings | 360 | |
Documented Sources | 361 | |
Failure to State Assumptions Regarding Cost Estimates in Assessment Reports | 362 | |
Lack of Editing and a Quality Assurance Review | 363 | |
Disputes Over Disclaimers | 364 | |
Failure to Write the Report as a Business-Decision Tool | 365 | |
Chapter 24 | Waste Contractor Audits | 367 |
Objective and Scope of a TSD Facility Audit Program | 369 | |
Internal Programs vs. External Programs | 370 | |
Conducting the TSD Facility Audit | 372 | |
Pre-Audit Preparation | 372 | |
Special Pre-Audit Considerations | 375 | |
Selecting the Audit Team | 378 | |
The On-Site Audit | 379 | |
The TSD Facility Audit Report | 383 | |
Conclusion | 385 | |
Chapter 25 | Waste Minimization or Pollution Prevention Audits | 387 |
Why a Pollution Prevention Focus? | 387 | |
The General Approaches | 388 | |
Limitations and Constraints | 389 | |
Methodology | 389 | |
Examples of the Presence of a Waste Minimization Effort | 393 | |
Chapter 26 | Evaluating Management Systems on EH&S Audits | 395 |
Why Evaluate Management Systems? | 395 | |
What is a Management System? | 396 | |
How Do You Do It? | 398 | |
Practical Tips | 400 | |
Why is It So Hard? | 401 | |
Conclusion | 402 | |
Chapter 27 | International EH&S Audits | 403 |
Role of Corporate Management | 405 | |
Design of International Audit Programs | 406 | |
Conducting International Audits | 410 | |
Summary of Key Challenges in International Audits | 413 | |
Appendices | ||
Appendix A | References | 419 |
Appendix B | Federal Register Notes | 423 |
Appendix C | Sample EPCRA Audit Protocol | 455 |
Appendix D | Problem Solving Exercises | 477 |
Appendix E | Summary of Audit Programs | 555 |
Appendix F | Model EH&S Audit Program Manual | 581 |
Appendix G | Model Pre-Audit Questionnaires for EH&S Audits | 615 |
Appendix H | Model EH&S Audit Opening Conference Presentation | 645 |
Appendix I | Model Environmental Audit Report | 653 |
Appendix J | Model Environmental Audit Appraisal Questionnaire | 671 |
Appendix K | Model Management Presentation | 675 |
Appendix L | Sample Site Assessment Report | 683 |
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