Learn how to handle an environmental audit at a data center.
One of the scariest words a professional can hear is "audit". We can all picture the image - someone with a badge, from a three-letter agency, is showing up to "audit" your operation. CIA, FBI, IRS, you name it, it's scary! But what about... environmental audits? Are they even applicable at a place like a data center?
Long story short, anyone within the data center industry should (at the very least) be aware of the term "environmental audits", why they're done, who might be auditing your operation, and most importantly, how to survive an environmental audit at a data center!
Let's cover a few key issues relating to environmental audits, clear the air, and help get you on the right path to easily handle any environmental auditing concern at your data center.
What's an environmental audit?
If you're completely new to the concept, here are some articles that may be helpful:
In short, an environmental audit is just like any other kind of "audit". It's a comprehensive review of your data center and the environmental regulations that apply to it, usually with some sort of "report" at the end to help gauge where you stand.
What's covered in an environmental audit at a data center?
A data center is a unique place, so an environmental audit occurring at one should uncover some pretty unique things, right?
While a data center isn't discharging hazardous waste or releasing pollution from giant smoke stacks, your facility is covered under some pretty universal environmental regulations, such as:
While those four might not sound like a lot, they cover the gambit from Federal regulations (SPCC Plans) to more localized considerations (Tier II Reporting).
A well-performed environmental audit is likely going to be looking (at a minimum) at those four areas of concern.
Who conducts an environmental audit at a data center?
Here's where things get interesting! There are really 4 key "groups" that will want to conduct an environmental audit at your data center, which roughly are:
The General Public
Your Own Company
Let's dive into each "group" and discuss when and why they may do an environmental audit at your data center.
Government Conducted Environmental Audits at Data Centers
Here's where a lot of our customers get confused regarding regulations, inspections, and getting visited by government officials.
Most times when a government official visits your data center, they aren't conducting an "environmental audit". Instead, they're there to conduct an inspection in relation to a specific environmental regulation. For example, you may have a local (state, county, regional, etc.) air inspector stop by your data center to review your facility, and determine whether or not you're in compliance with your air permit. This isn't an audit, it's a routine inspection done to make sure you are following the rules outlined in your air permit.
So in a sense, the government won't be doing environmental audits at your data center. Instead, they'll conduct routine inspections to make sure you're doing what a specific plan, permit, or approval outlines. These tend to be highly focused, high-level inspections, and not something focused on your overall operation.
Unlike getting audited by the IRS, it's pretty unlikely (but not 100% impossible) that the EPA, state environmental department, or anyone else will show up to do a comprehensive audit of your operation. Chalk this up to misunderstanding terms, but for most data centers, you are going to have an environmental audit done by a regulatory agency, ever.
Can the general public do an environmental audit of a data center?
Yes and no! Most regulations out there do allow for a limited amount of public interaction when it comes to facilities getting into, and staying in compliance, with environmental regulations.
For example, under certain environmental regulations, the general public (usually in the form of 3rd party citizen groups, like the Riverkeepers or the Sierra Club for example) can make your life pretty tough if you aren't in compliance, usually by suing your operation.
Yes, that's right, you can be sued for non-compliance.
In these instances, if your data center is out of compliance with an environmental rule, law, or regulation, the general public, from a single person to an organization, can sue you for not following the law. Most times when this happens, it's happening for a reason, and they know you aren't in compliance at your data center. In these cases, when you're caught red-handed, your only option (unless you spend money to lose in court) is to do what the public is asking and just get into compliance.
At a data center, easily identifiable things such as the presence of emergency backup generators, and easily researchable things such as looking up your facility's air permits and Tier II Reporting on online databases, allow the general public to "inspect" your operation from afar. Remember, things like Google Maps, environmental record databases maintained by the USEPA and state agencies, drones, Google Street View, and more, all make reviewing your operation from behind a keyboard a breeze.
So again like the government example, the general public can't really "audit" your data center per se, but rather can digitally and remotely inspect your operation to determine if you're in compliance or not. From our experience, when things like this occur, regardless of the industry, they tend to be focused on one specific area of environmental regulations but can open the door for cross-agency inspections, meaning your entire operation and environmental program is put under a microscope.
Customer & Vendor Based Environmental Audits at Data Centers
Here's the most common form of environmental audits we've run across while we've been working in the data center industry. Your customers, who happen to be some of the largest, savviest organizations in the history of our planet, generally put importance on things like environmental issues.
Since you're leasing part of your data center out for their needs, your customers may want to make sure that you too are placing importance on environmental issues, meaning they want proof.
What commonly happens is a customer will let you know that they want to conduct an environmental audit of your data center ahead of time (or not, there are surprise audits). These environmental audits will look at a few main areas of concern at a data center, and ask for information about where you stand, what you have in place, any compliance-related issues, etc., etc.
Sometimes a customer-based environmental audit at a data center is as simple as answering yes or no to a series of questions. Other times these audits may ask for additional information, such as air permit numbers, copies of last year's Tier II Reports, hazardous waste handling details, and more! It all depends on who's conducting the audit, how knowledgeable they are, and how deep they want to dive into your data center.
Additionally, sometimes these environmental audits at a data center will cover topics outside the realm of environmental matters, including addressing safety issues, which is a whole other ball game!
Data Center Company's Conducting Internal Environmental Audits
One of the great things about an environmental audit is it's a useful tool for gauging where you stand. It's like visiting a doctor or a dentist or even a mechanic on a regular basis. Let's take a look, see what's good, and what's bad, figure out where we stand, and do what's needed to move forward.
When companies in the data center industry conduct internal environmental audits, it's a useful tool to ensure they're in compliance with every applicable environmental regulation out there, preventing problems from popping up down the road with government inspectors, citizens and 3rd party groups, and customers!
Having said that, an internal environmental audit of a data center organization needs to be done carefully. For example, if you were to conduct an environmental audit of the data centers you're responsible for, are you really going to want to report to your upper management that you missed or didn't know about something, dropped the ball, and might be putting the company at risk? And what if your organization doesn't allow you to adequately address the non-compliance issues found? Now you have a paper trail illustrating you knew you were breaking the law and did nothing about it!
For these two reasons we recommend to anyone in any industry to:
Get an outside expert to conduct an environmental audit of your data center, and
Talk to knowledgeable, qualified legal counsel if you're serious about getting one done.
That way, an outside expert can work directly with your legal team, meaning you have an impartial outsider giving your data centers a thorough going over, plus you'll have the added benefit of attorney-client privilege communications. You won't have to worry about throwing yourself under the bus, won't have to worry about your employees trying to hide anything they may have missed, and won't have to worry about leaving a paper trail admitting you are out of compliance.
How to survive an environmental audit at a data center.
Ok, so now that we know why you might get audited, who's doing them, and why they're occurring, the simple question is, how do you successfully handle an environmental audit at a data center?
Simple. Be in compliance with every applicable environmental rule, law, and regulation, from the Federal to the local level.
I know, easier said than done. That's like saying how do you not get audited by the IRS? By paying your taxes correctly! Seems like a simple solution, but it's not always that easy.
It's often not as simple as just "following the rules" because the rules regarding environmental regulations can change (drastically) from state to state, county to county, region to region, and even city to city. Even locations within the same city may have different environmental regulations to deal with! Add in the simple fact that most environmental regulations are dozens if not hundreds of pages long, so trying to figure out what applies to your data canter can be a real chore.
Here's where we throw out a biased opinion - hire an outside expert. For the same reason, you go to a mechanic, hire a personal trainer, use an accountant, hire a plumber, or do anything else in life where you need expertise and results without wasting your time (and money), sometimes hiring an outside environmental professional (or even bringing on an Outsourced Environmental Department) makes the most sense in terms of expertise and costs.
Having said all that, here are some simple steps to make sure you're in compliance, so you can easily handle and survive an environmental audit at your data center:
Figure out what environmental regulations apply to your data center. Make sure that you are adequately covered or correctly handling your responsibilities with regard to the various forms of environmental regulations.
Conduct regular audits (internal or external). I cannot stress enough how important it is to make sure you are in, and staying in, compliance with every applicable regulation that applies to your data center.
Develop a system allowing you to easily handle and track your environmental responsibilities. Documentation and paperwork are the easiest way to get in trouble with a regulatory agency.
Conduct environmental training for your staff. That way if you're on vacation or at another data center across the country, your staff can handle simple regulatory details such as inspections or meetings with government regulators.
Stay educated. Keep your eyes and ears open for things that could impact your operation, ranging from Federal environmental initiatives (such as the recent push in environmental justice) to local considerations. Also, learn the difference between the EPA and a local city-level inspector.
Anticipate problems. Your staff is going to miss an inspection, your vendor is going to audit you while your entire company is on a corporate retreat, or worst case scenario, personal issues may prevent you from being on-site during a crisis. Plan ahead, train across the board, and set up an easy to use & access system for your environmental documents.
Keep your data center in compliance with environmental regulations.
These may all sound easy, but for folks out there with a heavy workload, wearing multiple hats, and responsible for several data centers, dealing with environmental regulations can be a real challenge.
If you aren't sure if you're in compliance or not, seek help. You don't want to find out the hard way when inspector issues you a several thousand dollar fine, or even worse, your customers decided to pull out of your data center.
Need a hand with environmental audits at your operation? If so, we're here to help. Reach out, let's talk, and see if getting an environmental audit is what your operation needs. To learn more, feel free to contact us online, send us an email at firstname.lastname@example.org, give us a call at 888-RMA-0230, or simply fill out the form below to get in touch.
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