After the Audit

Compliance findings are identified as a result of an environmental, health, and safety (EH&S) compliance review or audit. What happens next? Ideally the compliance review or audit report identifies compliance issues and provides recommendations or proposed corrective actions to achieve compliance with the regulatory requirement or to implement best practices. While the corrective action process may be a bit daunting, we want to point out some key approaches to take after the audit to ease your concerns:

1. DO NOT let the compliance findings sit idle. Whatever the reason for the compliance audit or review, the findings should be addressed.
2. Determine if (and how) to manage audit finding disclosure under EPA and state laws/policies (obtaining guidance from legal counsel BEFORE the audit is best).
3. Keep the findings visible internally and ensure that findings/proposed corrective actions are communicated to and understood by the management team and stakeholders. In turn, management should provide applicable personnel with authority to undertake corrective action.
4. Ensure that a process for correcting the findings is developed rapidly:
5. Prioritize the findings by risk (if not already completed). Be considerate of, but not limited to, cost consideration when prioritizing risk.
6. Develop and obtain approval for cost to correct the finding.
7. Assign responsibility to person(s) for the completion of the recommended corrective action(s).
8. Develop a timeline for implementation of the recommended action(s).
9. Record the completion of corrective actions, and review with the management team and others.
10. Consider reviewing the success of the corrective action in 1, 3, and/or 6 months. Or, if a future audit is conducted, ensure the previous audit report is available for review and discussion.
11. Establish an internal communication process to keep stakeholders abreast of progress and results (as correcting one issue could result in other issues occurring).

In some instances, corrective actions can be handled internally with no third-party assistance. However, should there be a need for assistance, select the qualified individual/company with:

• Expertise required to meet the goal
• Knowledge of the site/issue
• Defined scope and budget (no surprises)

EHS Support provides support to many of our clients beginning day 1 after an audit. We develop corrective actions plans, determine additional risk, implement EH&S corrective actions, train personnel, and verify effectiveness of corrective actions to promote success for our clients. We pride ourselves on our efficient and effective approach to the corrective action process, whether it be proactive or reactive. For those issues where corrective action was delayed and resulted in enforcement action, we can help you work with the regulators to resolve the issue.

[callout font_size=”13px” style=”golden”]After an audit, the corrective action process can seem daunting, but it doesn’t have to be.[/callout]
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