Independent audits and reviews are one very good way of evaluating a program objectively and accurately to determine vulnerabilities and risk. These plans and programs come in many forms and serve many purposes, ranging from EPA and OSHA compliance and Emergency Action Plans to Risk Management Plans, Worst-case Scenarios and Off-site Consequence Analysis to SPCC and RCRA contingency plans.

A related critical risk management tool follows an environmental incident, such as a spill or explosion, and is frequently referred to as an Emergency Response Review or “Hotwash.” Following the review, you may be asked to develop a “lessons learned” or “after-action report” to help do the job better and safer the next time. EPA or other Agencies often require this following an emergency response in which they were involved.

You may also have an audit or inspection scheduled by your corporation or a regulatory agency. Preparation is critical, and your best chance to minimize negative findings or potential misunderstandings is to resolve as much as possible right there during the inspection. Consider having your consultant there during the audit as a technical resource to answer the hard questions or interpret complex information. A good consultant knows how to do that, and can operate directly as part of the audit team.

Internal audits are often requested by legal staff, with the goal of making the results, or even the existence of the audit, work product between the attorney and the service providers. This may protect the audit from being “discovered” by regulatory agencies (EPA “Audit Policy” or OSHA’s treatment of voluntary audits), or from triggering mandatory disclosure on the part of the facility. Or it may not. Many issues can affect that, and protection may be lost by something as simple as making or distributing a copy of the audit outside the work product group. Follow the attorney’s lead on this.

Dr. Scott Harris is the Senior Risk Manager for IESO, LLC. His experience covers over 27 years of Environmental, Health and Safety Management in Federal and State government, consulting, general industry and University instruction.  He received his Ph.D. in Environmental Science, with a specialization in Disaster and Emergency Management, from Oklahoma State University, and holds degrees in Geology (B.S.) and Public Health (MPH) from Western Kentucky University.  Before joining IESO Scott was a Federal On-Scene Coordinator for EPA Region 6 and a member of their Emergency Readiness Team.  He held DOD “Top Secret” and DOE “Q” security clearances, and directed multi-agency emergency response, planning and recovery activities for chemical, biological and radiological releases and exercises within the five-state region.

Last 5 posts by Scott Harris

• IESO Presenting at 2010 ASSE Conference - December 7th, 2009
• IESO Adds Another PhD - December 1st, 2009
• Meet Us at St. Pete Beach in February! - November 4th, 2009
• EPA Greenhouse Gas Reporting Rule is Final - October 26th, 2009
• IESO Client Achieves ISO 14001 Certification! - October 23rd, 2009

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