Environmental Audit

An environmental audit is a type of evaluation intended to identify environmental compliance and management system implementation gaps, along with related corrective actions.

There are generally two different types of environmental audits:

  • Compliance audits

As the name implies, these audits are intended to review the site’s/company’s legal compliance status in an operational context. Compliance audits generally begin with determining the applicable compliance requirements against which the operations will be assessed.

This tends to include federal regulations, state regulations, permits and local ordinances/codes. In some cases, it may also include requirements within legal settlements.

Compliance audits may be multimedia or programmatic.

Multimedia audits involve identifying and auditing all environmental media (air, water, waste, etc.) that apply to the operation/company. Programmatic audits (which may also be called thematic or media-specific) are limited in scope to pre-identified regulatory areas, such as air.

Audits are also focused on operational aspects of a company/site, rather than the contamination status of the real property. Assessments, studies.

  • Management system audits

ISO 14001 is a voluntary international standard for environmental management systems (“EMS”). ISO 14001:2004 provides the requirements for an EMS and ISO 14004 gives general EMS guidelines. An EMS meeting the requirements of ISO 14001:2004 is a management tool enabling an organization of any size or type to:

  • Identify and control the environmental impact of its activities, products or services;
  • Improve its environmental performance continually, and
  • Implement a systematic approach to setting environmental objectives and targets, to achieving these and to demonstrating that they have been achieved.

Organizations implementing ISO 14001 usually seek to obtain certification by independent Certification Bodies. Certification indicates that the documentation, implementation and effectiveness of the EMS conform to the specific requirements of ISO 14001.

This standard is currently being updated to include elements of including a lifecycle perspective and including top management amongst other changes. The draft (DIS) standard ISODIS 14001:2014 is currently the draft standard applicable until the ISO 14001:2015 standard is finalised and published.

In 2002, the ISO organization also published ISO 19011, the standard for auditing quality and environmental management systems (ISO 19011:2002), which was used for internal audits and certification audits of EMS until it was updated in 2011. The 2011 version on ISO 19011 restricts its use in first and second part audits, while third part audits (certification audits) are now covered in ISO/IEC 17021.

A common misconception is that ISO 14001 certification automatically implies legal compliance. Certification under ISO 14001 does not directly reflect compliance with any legal requirements, although ISO 14001 demands the organization to evaluate its compliance with legal requirements.

If there is no compliance with some legal requirement, ISO 14001 requires that the organization sets specific targets related to the non-compliance(s) and establishes, implements and maintains programmes to achieve compliance. Therefore it is possible that, at the time of audit, the organization fulfils the requirements of ISO 14001, yet there are one or more non-compliances with specific requirements, which are identified and which the organization actively works to correct. Specific guidance on this subject is provided by the European co-operation for Accreditation.