Friday, May 30, 2008
"Nice doggy!": I was bitten by a junkyard dog while trying to take samples based on a complaint that the owner was dumping oil (at a junkyard - imagine that!). Once the incident was reported, the owner reported the dog missing for almost all of the 2-week rabies observation period. It looked like I was going to have to get the dreaded series of shots in the stomach, until the dog miraculously "reappeared" on the last day. Whew! But they don't call me "Mad Dog Molly" for nothing!
"The Stress Musta Got to 'Em":
There is nothing quite like the special ambiance of an emergency room for a closing meeting. My client was having dizzy spells and was uncontrollably nauseous, which is not necessarily abnormal at a closing meeting, but we did think this case was serious enough to go to the hospital. Fortunately he got better, and to this day claims it was NOT the audit, but a temporary loss of equilibrium in his ear after a cross-country flight.
"War" stories are sometimes an excellent way to encourage a client to open up and relax, but ghost stories? One client explained to me that he talks to ghosts that live on the other side of his backyard fence, and they tell him what to do. What can you do but nod your head, smile and try not to make any sudden movements?
Lovely Weather We're Having:
Having 3 tornado warnings in one afternoon was an excellent chance to test the effectiveness of emergency preparedness and response procedures at one organization. Plus, I had a ready-made pool of interviewees trapped there with me. Bonus! Hey, just like showbiz: the audit must go on!
As a rookie park ranger (19 years old), I was on patrol, when my veteran partner spotted someone with beer on the beach (which wasn't allowed), so he let me out to write my first ticket. While I was busily trying to figure out how to fill out the form, I was oblivious to everything else, including my perp, who was standing between his car door and the interior of the vehicle. My partner came up behind him, and grabbed the billy club he had been reaching for, brought it up and said" What's this?" I sure learned some important observation skills that day...
...and the "most evil" award goes to this one:
When I was a hazardous waste inspector for the Indiana Department of Environmental Management, I was involved in a case where the owner of a plating company was trying to sell off and/or dispose of all his chemicals so he could skip town. I got involved after the city shut off the company's sewer access and called IDEM in to investigate. The case ultimately wound up with the federal EPA. If it were a Master Card ad, it would go like this:
Fines for illegally discharging your untreated plating solution to the sewer: $5000.
Fines for illegally burning your hazardous waste in the parking lot: $25,000.
Getting ten years in the federal pen for trying to sell your polluted property to the city for use as a youth center: Priceless!
When it comes to figuring out how often and how many (audits, not adult beverages), it is helpful to remember that this not a ritual you do to fend off evil spirits, like vampires (and/or auditors).
Unlike rituals - stabbing voodoo dolls, sacrificing virgins (auditors) or bouts of heavy drinking - internal audits give you measurable data about environmental performance.
Ok, ok, I had you until that last part where I started to sound like a textbook. To clear up any confusion, here’s how Huggy Bear would say it: “Word on the street is, audits tell you what’s goin’ down!”
That’s right, internal audits enable the lonely, red-headed step-child environmental manager (no, a longer title does NOT equal more pay) to get in the loop and find out what’s really going on outside their dark little corner of the office, otherwise known as the broom closet.
What may be the most upsetting to some is that without a required number of audits, it is nearly impossible to plan an avoidance strategy, not that folks won’t still try. Here’s a good example: “If there is no requirement about how often you must audit, is auditing the entire system once every three years often enough?”
Geez! Don’t strain yourself! No, this would not be acceptable. You would fail to meet the requirement to base planning on previous results and environmental importance, not to mention it’s just silly! Audits are your window on the world; do you really want to fly blind for 3 years?
Avoidance strategies like this reflect a failure to see value in auditing. If auditing is something that is done only under extreme duress, you are missing the point of having an EMS. These attempts to side-step "extra work" may also reveal a fear of finding out that things really aren’t working and then having to pass that information along to managers. Ignorance is bliss, right?
I know it’s scary to show your soft underbelly to managers, but if environmental performance equals your personal performance as EMR, you have MUCH bigger problems (See “Taming Your Inner Scapegoat - An Owner’s Manual for Environmental Professionals” – coming soon!)
Remember, EMS is top-down: the buck stops with top management and they drive the system (not the EMR), so if something is not working because of inadequate resources, they are required to provide them. Audit data helps to create an accurate picture of performance; one that you show to your managers so you can get the resources you need: i.e., money, people, cash, equipment, $$$$, time, bucks, training, money, money, money). In other words, audit data is a lot like the PIN to your ATM card: you gotta have it before you can get the dough (or d‘oh!)
You know the old phrase "Money talks..."? Well, you want to make sure your audit data isn't the equivalent of the second half of that famous saying.
So hopefully now you understand that audit data are your "friends." But you may still be asking how audit frequency comes into play.
Do you want your audit data to show managers:
a) A one-time snapshot?
b) Trends that have developed over time?
If your answer was “b,” you get 1000 points on the EMS-O-Meter toward expert-EMR status. Congratulations! You know that the messenger relaying tomorrow’s potential problems is better off than the bearer of yesterday’s bad news.
As I have said before, the standard intends for you to do internal audits whenever you need the feedback they provide. So now that you know how to schedule audits, the trick is getting them done… AND getting them done right!! (See “Bad Audits and the Auditors Who Love Them” – coming soon!)
Wednesday, May 21, 2008
What the $^&@*! is a "full cycle" of audits? (See “EMS Registration: The Road to Becoming ‘Certifiable’” – coming soon!)
Will an audit a day keep the registrar away?
Well, let’s see: Element 4.5.5 requires audits to be conducted at “planned intervals,” whatever that means... So a simple schedule showing I audited all the elements in a year should work…