环境会计外文文献

EVOLUTION OF AN ENVIRONMENTAL AUDIT PROGRAM J. H. Maday T. L. Kuusinen October 1991 Presented at the Environmental Auditing Conference October 22-23, 1991 Seattle, Washington Work supported by the U.S. Department of Energy under Contract DE-ACO6-76RLO 1830 Pacific Northwest Laboratory Richland, Washington 99352 1 DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States。Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. Evolution of an Environmental Audit Program Joseph H. Maday, Jr. (ASQC-CQA) Technical Group Leader - Quality Verification Department and Tapio Kuusinen Senior Research Scientist Environmental Policy and Compliance Group Pacific Northwest Laboratory Richland, Washington 99352 ACKNOWLEDGEMENT This document was prepared under the direction of the U.S. Environment Protection Agency’s (EPA) Small Business Division. There were numerous reviewers from government and private organizations. Additionally, the following provided important advice and/or reference materials: * Small Business Ombudsman, Maine Department of Environmental Protection * Tennessee Small Business Assistance Program * New Jersey Department of Environmental Protection * Massachusetts Office of Technical Assistance for Toxics Use Reduction (OTA) * Iowa Waste Reduction Center, University of Northern Iowa * Florida Small Business Assistance Program The products and services included in this document were contributed for review by commercial and government sources. The project team is thankful for their timely cooperation. ABSTRACT International and national standards, and in some cases corporate policies require that planned and scheduled audits be performed to verify all aspects of environmental compliance and to determine effective implementation of the environmental management program. An example of this can be found in the definition of auditing as provided by U. S. Environmental Protection Agency (EPA) Policy Statement on Environmental Auditing. It defines environmental auditing as follows: "Environmental auditing is a systematic, documented, periodic and objective review by regulated entities of facility operations and practices related to meeting environmental requirements. Audits can be designed to accomplish any or all of the following: verify compliance with environmental requirements, evaluate the effectiveness of environmental management systems already in place, or assess risks from regulated and unregulated materials and practices. Auditing serves as a quality assurance check to help improve the effectiveness of basic environmental management by verifying that management practices are in place, functioning and adequate. '' Many specifications further emphasize that the audit be performed to written procedures or checklists (to provide later documentation) by personnel who do not have direct responsibility for performing the activities being audited. The results of such audits are generally required to be documented, reported to, and reviewed by, responsible management. Follow-up action will be taken where indicated. The responsible organization can then take follow-up action as needed. An effective auditing program is a useful tool for improving environmental compliance. If developed properly, the program will point out areas of weakness and areas of potential problems. An auditing program will also identify environmental compliance activities that meet or exceed expectations. At the Pacific Northwest Laboratory(PNL), Environmental Audits used to consist of nontechnical auditors auditing to findings published in General Accounting Office reports. Today's practice of deploying a composite team of technical specialists and nontechncial auditors to audit to specific environmental programmatic requirements provides, we believe, a significant improvement. 国际和国家的, 而且在一些情形企业的政策需要那了的和预定的稽核是运行到查证所有的环境服从的方面和决定环境管理的有效落实计画。这的一例子能在环境的收支检查上的 U. S. 环保署 (环保署) 政策陈述旁边的依照提供的收支检查的定义中被发现。它依下列各项定义环境的收支检查: "环境的收支检查是有系统,证明, 周期的和目检讨 被管理设备行动的实体和练习相关的到会议 环境的需求。稽核能是设计完成任何的或所有 下列各项: 查证符合环境的需求作法, 评估那 已经在地方的环境#管理#的效力, 或估定危险 从管理和紊乱的材料和练习。 收支检查服务当做教育学程认证检查到帮忙改善效力 基本环境的管理藉由查证管理实务是在 地方, 动作和适当的。 '' 多数规格更远的强调那稽核是运行到书面的程序或者人员的检查表 ( 提供更迟的文件) 做不有直接的对表演的$$1责任活动在稽查。如此的稽核的结果通常是必需的是证明, 到, 和检讨被, 有责任的管理。跟进行动将会被采取哪里指出。然后有责任的组织能拿依照需要的跟进行动。 一个有效的收支检查计画是改良环境的服从的一个有用的工具。如果发展适当地, 计画意志点外面的弱点区域和区域潜能问题。一个收支检查计画也意志监定环境的服从活动哪一会或超过期待。 在太平洋西北实验室 (PNL), 环境的稽核过去一直有对调查结果的非技术上审计官收支检查出版在审计处报告。部署的今天练习一合成物队技术上专家和nontechncial 审计官到稽核到特性环境的标题音乐的需求提供,我们相信, 重要的进步。 CREATING AN AUDIT PROGRAM: WHY AUDIT In the "Environmental Audit Program Design Guidelines for Federal Agencies,”(EPA/130/4-S9/001) the audit objectives are given: "The goal of environmental management is to reduce environmental pollution and minimize r isks associated with a facility’s production, operations and maintenance. An environmental management program oversees the environmental functions within an agency, generally providing guidance and technical support throughout the entire organization. An environmental audit program is a critical component of nn agency's ongoing environmental management program. Auditing increasingly, is being used as a systematic method for verifying compliance with applicable statutes and regulation, evaluating the effectiveness of environmental management systems already in place, and identifying unregulated risks present at a facility. In essence, environmental auditing provides the data for a facility, or agency to prepare a "report card" to ensure that the goals and objectives of their ongoing environmental program are achieved. The Environmental Protection Agency (EPA) defines environmental auditing as a systematic, documented, periodic and objective review of facility operations and practices related to meeting environmental requirements. '' The May 1984 guidance document, For Preparation of Combined Work/Quality Assurance Project Plans for Environmental Monitoring (OWRS QA-1), prepared by the EPA's Office of Water Regulations and Standards, requires in Section II that the Plan include a section addressing "Performance and System Audits." It states in part. "To the extent possible, these audits should be conducted by individuals who are not directly involved in the measurement process ....A Work/QA Project Plan should specify who will conduct the audit. what protocol will be used, what the acceptance criteria will be and to whom the audit reports will go." This is elaborated upon in the Appendix to the EPA’s "Elements of Effective Environmental Auditing Programs," as follows: ?Explicit top management support for environmental auditing and commitment to follow-up on audit findings. ?An environmental audit team separate from and independent of the persons and activities to be audited. ?Adequate team staffing and training. ?Explicit audit program objectives, scope, resources and frequency. ? A process which collects, analyzes, interprets and documents information sufficient to achieve audit objectives. ? A process which includes specific procedures to promptly prepare candid, clear and appropriate written reports on audit findings, corrective actions, and schedules for implementation. ? A process which includes quality assurance procedures to ensure the accuracy and thoroughness of environmental audits. Generally, the document authorizing work (i.e., a Statement of Work, or Contract) will specify, whether an audit program must be effected by the responsible organization. Assuming this to be the case, why do we audit? Here again, the guidance document identifies three purposes for performing audits: ?to determine if a particular group has the capability to conduct the monitoring before the project is initiated ?to verify that the QA Project Plan and associated "SOPs" are being implemented ?to detect and define problems so that immediate corrective action can begin. Perhaps on a less positive although valid note are additional reasons for performing audits: ?the 1986 decision by the. EPA to include Environmental Auditing provisions in enforcement settlements ?the litigious nature of our society. The prevalent theme of the purpose statements above is one of continuous improvement and recurrence prevention. Audits are a management tool for improvement of the program. AUDIT STANDARDS AND GUIDANCE This chapter presents process or qualification standards for conducting audits. These documents are relatively short and provide the user with essential information for designing an audit program, preparing for an audit, or evaluating auditors. The strength of these documents is that they provide information that is brief and easy-to-use. These documents can be used as planning checklists. The limitation of these documents is that they do not provide extensive background information or learning tools. Because they focus on the audit process or auditor qualifications, they also do not provide information on environmental requirements (e.g., regulations). While these documents may be essential for starting up an audit program, or understanding the components of an audit program, those looking for more in-depth understanding of auditing may need to seek additional materials or training to supplement this information. This document provides the required qualifications for an air compliance auditor for small businesses in New Jersey. Qualifications include professional experience, education, and specialized seminars related to air compliance auditing. These qualifications can be used to evaluate businesses that are considering hiring an outside auditor to review their operations with respect to air compliance. The document also provides guidance for small businesses in selecting an auditor, developing and negotiating contracts, and building a relationship with the auditor to assure that the needs of the small business are met. Despite its focus on New Jersey, the qualifications and the criteria are useful for any small business that needs to evaluate or select an auditor for conducting an audit against air compliance criteria. In contrast to audit standards, which define how an audit should be conducted, audit criteria define how the small business should be, or would like to be, operating. These criteria include regulatory requirements, such as federal, state, or local laws and regulations. They also include non-regulatory criteria such as environmental management systems standards, best management practices for businesses and agriculture, green product standards, or sustainable practice standards. Note that despite being not required, many of the “beyond compliance” criteria are crucial to the safe and efficient operation of a facility. Beyond compliance criteria in areas such as energy efficiency or environmental management systems (EMS) can reduce operating costs, allow small businesses to reduce their compliance requirements, and allow small businesses to constantly identify areas where environmental impact can be reduced. Furthermore, many businesses that generate hazardous waste are required by federal or state law to reduce the quantities of waste generated through pollution prevention. Thus, pollution prevention and EMS audit criteria provide opportunities for satisfying these requirements. 这一个章节礼物处理或资格引导的标准稽核。这些文件是相对地短而且提供必要的数据给使用者为设计稽核计画, 准备一稽核, 或评估审计官。这些文件的力量是他们提供数据哪一是摘要和简单易用。这些文件当做计划检查表能被用。这些文件的限制是他们做不提供广泛的背景数据或学问工具。因为他们在稽核上的焦点程序或审计官资格, 他们也做不提供关于环境的需求资讯.(举例来说, 规则) 这些文件可能是必要的对出发在稽核上面计画, 或理解成份一稽核计画, 正在找寻更多深入 的人理解收支检查可能需要到找寻另外的材料或训练到补充物这数据。 这份文件提供那必需的资格为一空气服从为新泽西州的小商店的审计官。资格包括专业人士经验,教育, 和特殊化研究会相关的到空气服从收支检查。这些资格能用来评估正在考虑的商店雇用一外面审计官用尊敬检讨他们的操作到空气服从。文件也在选择一个审计官方面提供指导给小的商店, 发展中的和谈判契约, 和建筑物和审 计官的关系保证那需要小生意是遇见。尽管在新泽西州、资格和标准上的它的焦点对任何的小生意是有用的哪一需要评估或选择引导的一个审计官一稽核反对空气服 从标准。 与稽查标准, 定义相反如何一稽核应该是引导, 稽核标准定义小的生意应该是如何, 或想要是,操作。这些标准包括管制的需求, 像是联邦的, 州, 或地方法律和规则。他们也包括非管制的标准,像是环境的管理制度标准, 最好为商店和农业,绿色的产品标准或足以支撑的练习标准的管理实务。不在乎不注意那必需的, 多数那 " 超过服从 " 标准是决定性的到那保险箱和设备的有效率的操作。超过服从标准在区域如此的当做能源效率或环境的管理制度 (EMS) 能减少操作费用, 让小的商店减少他们的服从需求, 而且让小的商店到不变地监定区域哪里环境的冲击能是减少。此外, 产生有害废物的多数商店是必需的被联邦的或者州法律减少量废物产生过污染预防。因此,污染预防和 EMS 稽核标准提供机会给满意的这些需求。 AUDIT TOOLS Audit tools are used to support or implement an audit program. Tools may include audit checklistsorprotocols that present audit criteria in a format that allows easier use by the auditor. Tools may alsoinclude audit finding ranking systems, compliance assistance documents or software, or any other material that the auditor would use during the audit process, not described in the other chapters. Organizational Placement Independence is one of the primary considerations to be given to any organization whose charter encompasses an audit function. The organizational nucleus of environmental auditors should be adequate to ensure objective and unencumbered inquiry, observation and testing. The objectivity of your environmental auditors should not be impaired bv personal relationships, financial encumbrances or other conflicts of interest that could impede free inquiry, or judgement. If the auditor is provided by an "Independent Audit Firm " this could mean the auditor is not to be a stockholder of the corporation being audited. The auditors must be free of real or perceived fears of retribution. Typically, companies establish audit programs within a core corporate group. In general, this group can be a function of the internal audit department, regulatory affairs department, legal, or environmental policy and compliance department. When evaluating independence of the auditing organization, consideration should be given to audit funding. If costs for performing the audit are absorbed as overhead and included in the budget of the organizational unit responsible for the environmental audit program, then independence may be inferred. Staffing and Training In a report to the EPA in February 1984, Arthur D. Little, Inc. stated: "Companies staff their environmental audit programs in a variety of ways. Most environmental audit teams include individuals with technical expertise, knowledge of environmental regulations, and plant experience. Several companies also include auditing expertise, knowledge of environmental management systems, and understanding of similar companies’ hazard control programs as staffing criteria .” SUSTAINING THE AUDIT PROGRAM Management support is best demonstrated by written policy articulating upper management support for the audit and for compliance with all applicable requirements, including the organization's corporate policies and permit requirements as well as pertinent federal, state, and local statutes and regulations. Management support for the auditing program may be further amplified by an explicit. written commitment to follow up on audit findings as to correct identified problems and preclude their recurrence. Documenting Benefits Environmental auditing includes a variety of compliance assessment techniques that. Go beyond those legally required and that identify actual and potential environmental problems. Effective environmental auditing can lead to higher levels of overall compliance and reduced risk to human health and the environment. The EPA mandates the practice of environmental auditing and supports its accelerated use by regulated entities to help meet the goals of federal, state, and local environmental requirements. A New Approach: The Multi-Discipline Team At the Pacific Northwest Laboratory we have had some success in performing joint audits with other verification entities such as Quality Assurance, Safety, Environmental Compliance, etc.. Joint audits allow us to maximize the benefits of having a strong audit team while minimizing the impact to the auditees' daily activities or operations. That is to say, rather than subject an organization to individual audits over a three month period. have the verification entities undertake a joint venture and audit the organization once a year. At the Pacific Northwest Laboratory, we seek generalists to manage or lead the audit team, but solicit specialists to balance out the team. For example, analytical chemists, soil scientists or hydrologists may be found at any given time assisting with a PNL audit. We have compared this team concept to the use of individual auditors and have found that the team approach to auditing brings more credibility to the audit and final report. Daily team caucuses allow an opportunity to discuss findings and areas of noncompliance. With specialists on the audit team, a "what if' question can be asked by the team leader and the specialist can understand the potential ramifications almost immediately. This team concept is particularly beneficial when conducting an environmental audit to evaluate performance or operational effectiveness. "Performance and systems audits are an essential part of every quality control program. A performance audit independently collects measurement data using performance evaluation samples. A systems audit consists of a review of the tota! data production process which includes on-site reviews of a field laboratory's operational systems and physical facilities for sampling, calibration, and measurement protocols.” This approach is particularly appropriate for environmental appraisals that must be conducted on nuclear facilities. For such an appraisal, the team would consist of a Safety Engineer, a Criticality Engineer, a Radiation Protection Specialist, a Safeguards and Security Specialist, a Quality Assurance Auditor, a specialist in Effluent Monitoring, and a representative from Facilities Engineering. 在那太平洋西北实验室我们有有表演的一些成功关节稽核与其他的确认实体,像是教育学程认证、安全,环境的服从, 等等。。关节稽核让我们最大值那利益有一强壮的稽核队当将减到最少的时候那冲击对 auditees' 每日的活动或操作。也就是说 , 并非主题一个组织到个体稽核在一个三月的时期之上。让确认实体从事一个共同投资和稽核每年一次的组织。 在太平洋西北实验室, 我们找寻通晓数门知识者处理或者领引稽核队, 但是请求专家到平衡外面的那队。举例来说, 分析的化学家、土壤科学家或水文学者可能是发现在任何的给予时间以 PNL 协助稽核。我们有比较这队观念到那使用个体审计官和有发现那队方法到收支检查带着较多的可信度到那稽核和结局报告。每日的队干部会议让一个机会讨论不服从的调查结果和区域。开着专家那稽核队, 一 "什么如果' 疑问能是问被那队领袖 而且专家能几乎立刻了解潜能分枝。当引导的时候,这一个队观念特别地有益一环境的稽核评估表现或操作的效力。 "表现和系统稽核是一个每个质量控制的必要部份计画。一个表现稽核独立地使用表现评估样品收集测量数据。一个系统稽核有 tota 的检讨! 包括的数据生产程序在-之上位置检讨一领域实验室的操作系统和抽取样品的身体的设备、口径测定和测量记录。” 这方法对一定是的环境的评价是特别地适当的引导在核子之上设备。对于如此的一个评价,队会有安全工程师, 临界工程师, 放射线保护专家, 一保护和安全专家、一个教育学程认证审计官,一个专家在流出的监听, 和一代表从设备工程学。 在那太平洋西北实验室我们有有表演的一些成功关节稽核与其他的确认实体,像是教育学程认证、安全,环境的服从, 等等。。关节稽核让我们最大值那利益有一强壮的稽核队当将减到最少的时候那冲击对 auditees' 每日的活动或操作。也就是说 , 并非主题一个组织到个体稽核在一个三月的时期之上。让确认实体从事一个共同投资和稽核每年一次的组织。 在太平洋西北实验室, 我们找寻通晓数门知识者处理或者领引稽核队, 但是请求专家到平衡外面的那队。举例来说, 分析的化学家、土壤科学家或水文学者可能是发现在任何的给予时间以 PNL 协助稽核。我们有比较这队观念到那使用个体审计官和有发现那队方法到收支检查带着较多的可信度到那稽核和结局报告。每日的队干部会议让一个机会讨论不服从的调查结果和区域。开着专家那稽核队, 一 "什么如果' 疑问能是问被那队领袖 而且专家能几乎立刻了解潜能分枝。当引导的时候,这一个队观念特别地有益一环境的稽核评估表现或操作的效力。 "表现和系统稽核是一个每个质量控制的必要部份计画。一个表现稽核独立地使用表现评估样品收集测量数据。一个系统稽核有 tota 的检讨! 包括的数据生产程序在 -之上位置检讨一领域实验室的操作系统和抽取样品的身体的设备、口径测定和测量记录。” 这方法对一定是的环境的评价是特别地适当的引导在核子之上设备。对于如此的一个评价,队会有安全工程师, 临界工程师, 放射线保护专家, 一保护和安全专家、一个教育学程认证审计官,一个专家在流出的监听, 和一代表从设备工程学。 LONG TERM TRENDS With the public sector demanding greater accountability from government regulators and industry a growing trend will be toward more audits and "self assessments." This trend will in turn cause the auditing organizations to work smarter, not harder. Certification and, in some instances, licensing may be required of those who will perform audits in the future. Government environmental programs have, and will continue to. evolve along a continuum of policy options. One such trend is from a near-total reliance on command and control approaches to a broader mix of activities which include more emphasis on innovation and education. The figure below illustrates this idea: The declining role of command and control strategies in new environmental programs means that environmental audits throughout the balance of the 1990s may focus less on compliance with requirements and more on performance, vis-a-vis less well defined expectations. The sources of such expectations are varied and will have a strong marketplace orientation. This means environmental auditors will need to become more fluent with core corporate business management systems in order to be effective. Greater integration of environmental management with other types of business management will help broaden advancement opportunities for environmental auditors. Avoiding Auditor Burnout Some might be of the opinion that quality assurance auditors are not effective after two years because "they become fuzzy-headed, frustrated, and burned out." Considering the time and cost that an organization invests in developing its auditors. this is a rather disturbing statement. If there is credibility to such a statement, we would be wise to pursue the root cause by asking, "Why is this happening'?" Has the auditor in question had some "tough" audits to perform? Is corrective action part of the program to preclude recurrence, or is it a "quick fix"to appease the auditor'? Have people within the audited organization been fired after an audit was conducted in their area of cognizance? These factors may all contribute to auditor burnout. It is incumbent upon the manager or supervisor of the audit function to watch for the symptoms and take the necessary, actions to avoid auditor burnout, and to keep the individual functioning as a contributing member of the team. The manager must provide the auditor with the appropriate incentive to maintain high levels of performance. The auditor could be sent to a job related training class or seminar. The manager could provide an "easier" assignment, or include the auditor as a part of a training curriculum. The manager should do what it takes to retain the talent that the organization has helped to develop. In some corporations, growth slots or entry levels are provided within the auditing organization to allow rotation of staff. One word of caution: do not allow a newly-hired individual to conduct audits without the direct supervision of an experienced auditor. The credibility of your auditing program could be jeopardized if an uninitiated entity is unleashed on the unsuspecting masses. CONCLUSION Within todays corporate culture, auditors and auditees alike, have been assigned stewardship over the environment. Audits provide a quality assurance check to contribute to the verification process, helping to ensure the management practices associated with the environmental management system are in place, functioning, and adequate. The objective of the audit is to help improve the effectiveness of that basic management system while at the same time determining compliance with the environmental requirements. Performing the audit in a well documented manner, using technically knowledgeable teams, will provide defendable benefits should the audit be challenged and will enhance the credibility of the existing environmental management system. 16