To Everything, There is a Season... Audit Planning Follies Part 1

Do I have to audit all elements of the standard within a year?

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?

These are the questions that keep environmental managers up at night… or at least the night before their registration audit.

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…

But… wait a minute... What’s this gobble-de-gook in paragraph 2: “Audit programme(s) shall be planned, established, implemented and maintained by the organization, taking into consideration the environmental importance of the operation(s) concerned and the results of previous audits.”??? Huh??? Why can’t they just say what they mean??!!!!!!

What, you want more clarification? Well, alrighty then. How about our good friend (and would-be rapper) TC 207? This roundabout requirement is mirrored - in two-part harmony no less - by COIs 02-03.A1 and 02-03.A2. After reading them, I promise, everything will be clear… as mud.

Don't know what a TC 207 COI is? See "Dr Strangeaudit or: How I Learned to Stop Worrying and Read the COIs."

Still itching for a numbers fix? I’ll try to explain in plain English: You audit when you need to.

It all boils down to that pesky 25-cent phrase: “planned intervals,” which miserably failed to clarify equally vague “periodically” used in the 1996 standard.

So is an interval the same as a “period”? If yes, then what’s a "period"? Is there a standard accepted timeframe that any auditor (no matter how dense) can recognize as a "period"? Whoah there! All this talk about periods is enough to give anyone PMS! To quote Foghorn Leghorn:: “I gotta straighten this lad out; thing like this could warp his mind for life.”

Look, take some ibuprofen, dry your eyes and cheer up. The "party animals" who went to the TC 207 site and read the COIs already know that there is no bare minimum number of audits you can “get away with.” Yep, that’s right. Playing dodge ball around an arbitrary number is not an option here. But there is still a silver lining: in a freak accident of common sense, the standard writers decided to require you to base your audit needs on:

1. What is important to your organization (NOT your registrar auditor), and

2. What has been a problem in the past

This means you focus on your problem areas, both actual and potential. Let’s face it: in the world of environmental management, things are constantly changing, and usually not for the better. Controls seem to fail when it’s most inconvenient, and even relatively good days still have nagging glitches. Then, there are always nasty surprises like mystery drums left by naughty “elves” in the middle of the night. Wouldn’t it be great to catch the problems before they blew up in your face, instead of being constantly blind-sided?

Internal audits help you do this because (if you do them right, and look beyond the "safe zones" of what's already working) they give you consistent, accurate and regular data about how your attempts at environmental control are performing, so you can quickly respond to small problems before they get out of hand. If you do enough good audits of the right things, they might even help you see a problem before it happens and prevent it!! You move from REactive to PROactive.

But I still hear whining: “That doesn’t answer the question how often and how many! Give us a number, we just want a number, surely there must be a number?!!!! WAAAAHHHH!!!!”

Well, just like other addicts, the whiners can’t help it. They have been brainwashed and need their number fix. There are lots of meaningless and arbitrary numbers out there - in permits, in regulations, or (if you really screw up) on your prison-issued clothing. And really, we are all in the same boat with the whiners because, even though enforcement of these numbers is capricious and inconsistent, we all want to believe that, if we meet the numbers, or get under or around them, everything is ok, even when it really isn’t. The reality is more like Lucy swiping the football out from under Charlie Brown – as soon as you are convinced it’s OK, the game changes.

Without our numbers, we often feel like a blind person trying to climb Mount Everest. But you still have “Sherpas” to guide you through this audit scheduling wilderness. You want numbers? Here are 5 things to consider when planning your audits:

1. Applicable legal requirements

2. Significant aspects

3. Corrective and preventative actions

4. Objectives and targets and

5. COMMON SENSE!

Numbers 1-4 are indicators of environmental performance, so they should be audited regularly; how regularly depends on number 5. The EMS does not exist in a vacuum, and you should always listen to your inner reason!