Auditing Treatment, Storage and Disposal Facilities - Non-Visit Audit

[Stijloor]

Re: Auditing Treatment, Storage, and Disposal Facilities

In one case the company is ISO 14001 certified. Would that be considered proof?

Certification only demonstrates that at the time of the audit, the system was compliant. It does not demonstrate ongoing compliance/effectiveness. As my Fellow Cover Phil Fields already stated, why would you not go there and see/verify first hand?

Stijloor.

 

[vsedriver]

Re: Auditing Treatment, Storage, and Disposal Facilities

Certification only demonstrates that at the time of the audit, the system was compliant. It does not demonstrate ongoing compliance/effectiveness. As my Fellow Cover Phil Fields already stated, why would you not go there and see/verify first hand?

Stijloor.

The main reason for not doing an onsite audit is cost and time. Funds are very tight right now and in one case I'd have to travel a considerable distance. The purpose of the audit is to confirm that our environmental goals are being followed in that we are not allowing any of our waste to be mishandled.

 

[tigerfan51]

Re: Auditing Treatment, Storage, and Disposal Facilities

If you are in the automotive sector it would be hard to justify the expense of a site visit right now. There are lots of regulatory compliance and technology factors that you can look at to help you confirm the adequacy of your waste suppliers:

1. Do they have all the required Local/State/Provincial/Federal environmental/operating approvals? Are the approvals in good standing?
2. What technologies/equipment/facilities do they use/have?
3. Have any NOVs (notices of violation), citations, fines been issued to/against them?
4. Are there any current legal actions/court cases against/pending against them?
5. What were the results of recent regulatory agency inspections, can you get copies of the reports?
6. Contact regulatory agencies and ask for their opinion/comments on your supplier's operations/facilities. Contacting community emergency response agencies may also provide valuable insight re the facilities.
7. Ask for copies of recent ISO 14001 audit results (for the supplier that is certified).
8. Ask them about their programs to ensure ongoing compliance at their facility (ie. staff dedicated to compliance/self inspections/auditing)
9. Have they had any recent spills, incidents, releases, complaints? How were recent incidents mitigated?
10. Are there any historical contamination issues at their sites? If yes, how are they being handled?
11. What disposal/treatment suppliers do they use (for final disposal of your wastes) and do their suppliers all have the required approvals?
12: Who are some of their other major clients and can you contact them for more info?

If you get positive (good, acceptable) answeres to all of these questions then it would probably be overkill to visit the site.

By the way, I would not rely just on info supplied by the supplier, I would also want to independently confirm at least some of what they tell you.

 

[Phil Fields]

Re: Auditing Treatment, Storage, and Disposal Facilities

If you are in the automotive sector it would be hard to justify the expense of a site visit right now. There are lots of regulatory compliance and technology factors that you can look at to help you confirm the adequacy of your waste suppliers:

1. Do they have all the required Local/State/Provincial/Federal environmental/operating approvals? Are the approvals in good standing?
2. What technologies/equipment/facilities do they use/have?
3. Have any NOVs (notices of violation), citations, fines been issued to/against them?
4. Are there any current legal actions/court cases against/pending against them?
5. What were the results of recent regulatory agency inspections, can you get copies of the reports?
6. Contact regulatory agencies and ask for their opinion/comments on your supplier's operations/facilities. Contacting community emergency response agencies may also provide valuable insight re the facilities.
7. Ask for copies of recent ISO 14001 audit results (for the supplier that is certified).
8. Ask them about their programs to ensure ongoing compliance at their facility (ie. staff dedicated to compliance/self inspections/auditing)
9. Have they had any recent spills, incidents, releases, complaints? How were recent incidents mitigated?
10. Are there any historical contamination issues at their sites? If yes, how are they being handled?
11. What disposal/treatment suppliers do they use (for final disposal of your wastes) and do their suppliers all have the required approvals?
12: Who are some of their other major clients and can you contact them for more info?

If you get positive (good, acceptable) answeres to all of these questions then it would probably be overkill to visit the site.

By the way, I would not rely just on info supplied by the supplier, I would also want to independently confirm at least some of what they tell you.

Very good reply!

Phil (waiting for Randy's resposne)

 

[vsedriver]

Re: Auditing Treatment, Storage, and Disposal Facilities

If you are in the automotive sector it would be hard to justify the expense of a site visit right now. There are lots of regulatory compliance and technology factors that you can look at to help you confirm the adequacy of your waste suppliers:

1. Do they have all the required Local/State/Provincial/Federal environmental/operating approvals? Are the approvals in good standing?
2. What technologies/equipment/facilities do they use/have?
3. Have any NOVs (notices of violation), citations, fines been issued to/against them?
4. Are there any current legal actions/court cases against/pending against them?
5. What were the results of recent regulatory agency inspections, can you get copies of the reports?
6. Contact regulatory agencies and ask for their opinion/comments on your supplier's operations/facilities. Contacting community emergency response agencies may also provide valuable insight re the facilities.
7. Ask for copies of recent ISO 14001 audit results (for the supplier that is certified).
8. Ask them about their programs to ensure ongoing compliance at their facility (ie. staff dedicated to compliance/self inspections/auditing)
9. Have they had any recent spills, incidents, releases, complaints? How were recent incidents mitigated?
10. Are there any historical contamination issues at their sites? If yes, how are they being handled?
11. What disposal/treatment suppliers do they use (for final disposal of your wastes) and do their suppliers all have the required approvals?
12: Who are some of their other major clients and can you contact them for more info?

If you get positive (good, acceptable) answeres to all of these questions then it would probably be overkill to visit the site.

By the way, I would not rely just on info supplied by the supplier, I would also want to independently confirm at least some of what they tell you.

thanks this tells me more about what I need to know and do. We are not in the automotive business but the recycling industry and things are really, really slow so money is very tight. But I don't want our ISO plan to fall by the wayside.

 

[Randy]

Re: Auditing Treatment, Storage, and Disposal Facilities

I need to do an audit of our Treatment, Storage, and Disposal Facilities for our ISO 14001 program. Do I need to actually visit these places or is there documentation I could request that would do the same job?

If you have to ask, you're not the right person to audit a TSDF.

Auditing a TSDF, especially against ISO 14001 and according to your statement is very technical and definitely requires a high level of competence

The purpose of the audit is to confirm that our environmental goals are being followed in that we are not allowing any of our waste to be mishandled.

I am a TSDF auditor and you have to do the audit hands on, not by mail and not by..."Oh yeah, we're managing everything OK, trust us"

Your company has both civil and criminal liability and "cradle-to-grave" responsibility for the waste you have sent to that site (Oh, this can include you as an individual outside the protective corporate umbrella as well). That means "forever".

A TSDF is nothing to take lightly and just trust to an email and promise my friend.

 

[Stijloor]

Re: Auditing Treatment, Storage, and Disposal Facilities

Randy,

We were all waiting for your

Stijloor.

 

[Karen-Dawn]

Re: Auditing Treatment, Storage, and Disposal Facilities

We have a major waste handler that is also quite a distance and we rotate between the physical audits and having them sendus copies of either their own ISO audits or regulatory reports in years we dont want to travel. We make the trip every two or three years. If the company is as trustworthy and reputable as they say they should be glad to show you their compliance as ours is. I would assume some of the info and or any infractions they may have had would also be public info and available on line as well. (I am not up on US laws). Bottom line we like the system as we can see how they perform environmentally as a business and we can really spend the time and focus on our specific waste streams when we do the physical audit...

 

[Randy]

Re: Auditing Treatment, Storage, and Disposal Facilities - Non-Visit Audit

You know, that's all well and good Karen-Dawn, but how do you really know that an apple pie tastes good unless you taste it yourself?....The same holds true here. As a former environmental professional for a major corporation that got caught up in the old "Trust me" game like the one being described here I can tell you that you can't trust what you see many times, much less what someone assures you of.

In cases like this saying "we can't" means "we don't want to". What do you think costs less, a trip, a couple of hotel nights, a car rental and some meals, or a million $ of litigation expense?

 

[Karen-Dawn]

I do appreciate what you are saying Randy. I just dont believe you need to over-indulge in consuming the pie once you have tasted it. Depending on the 'risk' and once you have developed a trust. Showing interest even when you are not in their face auditing goes a long way in developing relationships and that trust. If you do it right suppliers will 'believe' you truly care about the environment and aren't just fulfulling an ISO requirement and it can allow you to audit a little less frequently helping that bottom line...