Environmental Regulatory Compliance Audit Frequency

[Cheryl]

BorisS you are correct.
Our organization has in the past (every 3 years) used an external organization to come in and audit us for compliance to legislations.

Internally on a semi-annual basis we conduct audits to ensure ongoing conformance to the programs and procedures that we have put in place to meet legislation requirements.

Additionally, we subscribe to e-laws to ensure we are aware of changing circumstances that may have an impact.

With no changes to e-laws or to our business the question arose as to why we are paying the extra costs to have an external organization come in and tell us we are still compliant. We have now changed our procedure to read "as required or 5 years".

 

[Paul Simpson]

BorisS you are correct.
Our organization has in the past (every 3 years) used an external organization to come in and audit us for compliance to legislations.

Thanks, Cheryl. I'm just glad I'm not that far off the pace! An independent external review can be helpful to give senior management confience that they are legally compliant but it is not a requirement if your internal systems work well.

Internally on a semi-annual basis we conduct audits to ensure ongoing conformance to the programs and procedures that we have put in place to meet legislation requirements.

That is going a long way to meeting the 14k requirement - perhaps all of it

Additionally, we subscribe to e-laws to ensure we are aware of changing circumstances that may have an impact.

Although this is 4.3.2 it has a large influence on this clause. So under 4.3.2. you have to have a procedure (documented or not) to establish what laws apply to you and to evaluate the implications for your organization.

Part of the implication may be another legal requirement you have to comply with and this then has to go into your 'Regulatory compliance' procedure and have to be checked every so often.

With no changes to e-laws or to our business the question arose as to why we are paying the extra costs to have an external organization come in and tell us we are still compliant. We have now changed our procedure to read "as required or 5 years".

Why not just change your documented procedure to state that your semi annual audit is the evaluation of compliance and results are then reviewed at your Management Review meeting?

 

[Ltibert]

The short answer is that it depends. You need to determine the amount and type of regulatory and other requirements based on your operation. If you have a strong handle on these requirements and your operations are not governed by many requirements, then it is possible that a timeframe of 5 years is appropriate. The issue is "risk" of non-compliance based on changes to these requirements. Most regulatory agencies tend to issue new requirements which may or may not impact you.

 

[Bill Mitchell]

To extend this out beyond 3 years will probably cause an issue with your Registrar. Generally the require this review a minimum of once per certification cycle.