TCEQAuditor Criteria

andThird Party Audit Protocol

EMS Stakeholder Meeting

April 23, 2003

Rule: Auditor Criteria

IndependenceExperience

– EMS programs– Environmental regulatory programs– Auditing

EducationCertifications grantedOther as required

Auditor Certifications

Lead auditor certification– ANSI-RAB– BEAC– IRCA– Others if at least as stringent

Rely on certification bodies

Independence

Cannot audit your workNo EMS consulting

– Two years prior– Two years future

No EMS developmentNo EMS software, toolsFinancial and managerial independenceThird party only

– Different employing company

Third Party Audit Framework

As if performed by TCEQIndividual audit approval

– No pre-approval for audits– No approved auditor list

Rule: Third Party Audit Protocol

Protocols meet the same requirements as the TCEQ audit protocols

Documentation provides information comparable to TCEQ audit

Method of audit review – Time review of documentation versus

field observation and personnel interviews to confirm performance

TCEQ Audit Oversight

After Third Party Audit– 20% reaudited by TCEQ

Joint Audit– TCEQ participation– Assure meets TCEQ protocol

Third Party/TCEQ Joint Audit

Coordinated audit plan (bid spec)Multiple objectives

– ISO– Responsible Care– TCEQ

Surveillance/CertificationScope Sufficient time

Audit Protocol

Audit elements for each standard– Documents – Interviews– Observations

Audit decision matrix

Element DocumentReview

Interview Observation

Aspects accurately identified, both regulated and non-regulated-Key activities, processes, products, services assessedfor inclusion in scope-all significant impacts accounted for-all regulated areas accounted for

-List ofAspects, List ofActivities, Listof Regulations

-EnvironmentalManager

-Activities,processes ,servicesincluded inscope whereappropriate

Aspect information and legal requirements are kept up-to-date, for example through periodic review to ensurethat operational changes and new regulations are takeninto consideration

Results of aspect identification and legal requirementsare documented.

Environmental risks and impacts associated withemergency situations and non-routine activitiesincluded in aspect analysis

- emergencypreparednessplan, Emissionevent and spillrecords

-EnvironmentalManager,Maintenance,Employees

-Emergencysituations andnon-routineoperationsincluded

Aspect Audit Elements

Table 10: Examples of Reasons for Approval, Conditional Approval or Denial

Elements Approval Conditionally Approval Denial

Aspects PAccurately identified anddocumentedPEmergency and non-routine situations included

PAspects not kept up todate

PSignificant aspects notidentifiedPEmergency and non-routinesituations not included

Prioritization PBased on significance ofenvironmental impact

PNot kept up to date PNot based on significance ofenvironmental impact

Compliance Screen

Cooperate– TCEQ

• Compliance History

• Other

– Third party auditor– EPA

Documentation

Pre-assessmentOn-siteReview and report

Pre-Assessment Documentation

Environmental policy Scope of the EMS Prioritized aspects Goals for continuous

improvement in environmental performance

Goals for ensuring compliance

Performance indicators

Independent or third-party reviews or certifications

Point of contact Regulatory incentives Pre-assessment questionnaire

that includes environmental, process, and operational background information

Signature certifies true, accurate, and complete

Leader Preassessment Docs

Three references stakeholder involvement – Community/citizens groups– Tribal or local regulator– Other community/local reference.

One reference community outreach effort

On-Site Documentation

Lead auditor name, contact information, and documentation of EMS-LA certification

Names and contact information of other auditorsOrganizational affiliationSigned certification by the lead auditor and team

consulting and independence criteria Signed certification of senior manager of auditing

organization auditing organization financially independent from auditee

Date(s) of audit and audit timeline

On-Site Documentation

Facility descriptionList of people interviewed during the audit Interview field notesList of documents reviewed before and during the

auditList of areas observed Field notes from observation Justification for any substantial areas not visitedHow planned operational changes have been

included in EMS

Review Documentation

Assessment findingsLists of non-conformances

– Classified by major, moderate, and minor– Described and tied to TCEQ EMS clauses

Final Decision

TCEQ decisionThird Party Audit reportTCEQ observationsEPA input for Leader