Environmental Audit

Any manufacturing activity being conducted by a business entity may or may not involve the generation of any kind of pollution, be it air, water or noise pollution. As per the Central & State Pollution Control Board guidelines, these manufacturing activities are considered white or green category business activities.

Then there are orange & red category of manufacturing activities, which involve generation of air pollution or water, noise pollution. For this, the installation of pollution control devices such as ETP, STPs, Dust collector, besides other pollution control measures are undertaken to mitigate the effect of manufacturing activity.

The Environmental Audit is performed at regular intervals to check whether the pollution control devices & other pollution control measures being undertaken are effective or not, whether more is required to be done to further tighten the grip around generation and control of pollution.

The process of Environmental auditing is an organized, scientific and time interval-based technique to ascertain a manufacturing entity ’s effectiveness & efficiency for:

How the business entity is performing on relevant statutory and internal requirements

Ensuring that top management is monitoring the environmental practices

Creating awareness & promoting good environmental management

Maintaining credibility with the public that our future generations will be free from pollution

Regular training & workshops for staff awareness and enforcing commitment to departmental environmental policy

Continuously exploring improvement opportunities for fighting pollution

Establishing the minimum standards for developing a credible Environmental Management System (EMS)

The process of Environmental Audit consists of following three phases.

Pre – Audit phase

Audit Phase

Post – Audit phase

Pre-Audit Phase

At the pre-audit stage, the business entity desirous of Environmental Audit is required to allot human & other resources for the whole audit process. The business entity is also needed to prepare an audit plan and the documents required for the environmental audit.  

Audit Phase

After the pre-audit phase is complete, the business entity may proceed with the actual audit. The audit team is expected to follow the standards & procedures laid down during the pre-audit phase. The audit team in this phase is required to conduct site inspections and interviews, evaluate teams and perform document reviews, as per the guidelines of the Govt. Environment Body.  After this is done, the audit lead team is required to prepare thorough Environmental Audit Reports.  

Post - Audit Phase

In the Post-Audit phase, the Audit team should reflect on the data generated and reports of environmental audit thus prepared so that the areas of improvement could be found out and steps to mitigate the pollution are undertaken.  

There are three main types of environmental audits that a company may conduct. These are as follows:

Environmental compliance

Environmental Management System (EMS) audits

Functional environmental audits

Environmental Compliance Audits

Environmental compliance audits, as the name suggests, determines whether the business entity is compliant regarding those particular pollution control devices and pollution control measures which were delineated during the issuance of the State/ Central Pollution Control Certificate.

Every manufacturing activity is required to get a certificate from State Pollution Control Board. When a Pollution Certificate is issued, the requirements of pollution control device & other pollution control measures are mentioned in the Pollution Board Certificate. The focus of the environmental compliance audit is to ascertain whether the business entity is following all or most of the parameters as mentioned in the Pollution Board Certificate. Other Pollution Board certificate such as Environment Impact Assessment – Environment Clearance (EIA-EC) also includes the conditions which are required to be fulfil during the operation of a particular manufacturing/infrastructure/mining activity.

Environmental Management System (EMS) audits

The Environmental Management System (EMS) Audits is an audit process in which the EMS of an organization, engaged in manufacturing, infrastructure development or mining, is evaluated to ascertain whether the system is effective enough to maintain the benchmark performance of the pollution control devices and other pollution control measures. The EMS Audit is conducted as per the guidelines of Clause 9 of the ISO 14001:2015. This performance is done to ensure:

That the Environmental Management System is proving effective in monitoring & controlling the air, water & noise pollution.

The EMS is properly inspected in terms of its expected performance standards.

The evaluation of objective of the EMS and its targets is undertaken.

To identify new targets or opportunities.

Ascertaining whether the EMS is fulfilling the organizational, stakeholder and legal requirements.

Periodic Review of the EMS for its perpetual suitability, adequacy and effectiveness.

To ensure continual improvement in a particular EMS.

Functional Environmental Audits

Functional Environmental Audit is a process under which specific compliance conditions are monitored and inspected for adherence to the Pollution Control Board Guidelines. For example, if an Effluent Treatment Plant (ETP) or a Sewage Treatment Plant (STP) is installed as a pollution control device to check water pollution, then the functional environmental audit would be focused on whether the treated water from the outlet of the ETP or STP satisfies the limits of concentration of hazardous materials in the treated water, if it is found to be wanting on these parameters, then the functional environmental audit would suggest the measures to be taken to mend this leakage of pollutants in the water body.

The first document required for an Environmental Audit is the site plan, layout plan or key plan. This is required to define the scope of the audit along with any changes done to the premises

The Consent to Establish (CTE), Consent to Operate (CTO), Environmental Clearance (EIA-EC) certificates, along with any EPR certificate, if the Business entity is engaged in plastic, electronics, battery or tyre manufacturing or import.

Previous environmental inspection reports and checklists to ascertain that inspections have been conducted and recorded at regular time intervals. The Hazardous waste manifests, sampling data, and other inspection reports are also required to establish a sound record keeping.

The raw purchase data, units manufactured & distribution, of all chemicals and other raw materials used, their locations, and quantities to find out the environmental regulations applicable to the facility.

The documents about Environmental Plans and procedures, best management practices and other applicable documents to show how the business entity is managing environmental issues and preventing problems. Also required are the EPA Risk Management Plan, Standard Operating Procedures (SOP’s) and written emergency response programs, if applicable.

The training records of technical persons, radiation safety official, chemical handing certificate etc to ensure that the employees are adequately trained to handle their daily tasks. The medical reports of some employees to ascertain whether the work of the employee is any anyway affecting his/her physical health.