Who Can Do an Environmental Audit (and Can I Do One Myself)?

How to Choose the Right Auditor for Your Environmental Audit

Environmental audits provide tremendous benefits to businesses and industry, yet can seem to be mysterious and complicated to most. One question that's often asked is: who can do an environmental audit, or can we have someone within our own company do it?

These are great questions, since having the wrong person do your environmental audit might not deliver the results you wanted, and could in fact get you in deeper trouble than if you hadn't done the audit in the first place. The short answer? It's always best to hire a professional to conduct an environmental audit!

The longer answer? Let's jump in and discuss who can do an environmental audit, and who shouldn't!

An Environmental "Doctor's Appointment" for Your Business

If you've read this far, you've probably heard our commonly-used analogy between environmental auditing and getting your annual medical checkup from your doctor.

Just like getting that annual checkup, a regular environmental audit can keep you in great regulatory compliance health, safeguard your business, and allow you to sleep easy knowing that you have nothing to worry about.

Sounds like a winner, right?

So... Who is Your Doctor?

One of the keys to this analogy is your doctor. Who is he or she? They're professionals, highly trained and skilled in their fields, and capable of evaluating you relative to a common set of criteria and standards (like your blood pressure, cholesterol levels, and overall general good health criteria).

You go to them since you know they're experts, they can provide you with a comprehensive evaluation, and you probably don't have the kind of knowledge that they do.

• You probably wouldn't do your own annual physical, would you? Of course not, you're not a medical expert.
• You probably also wouldn't go to a foot doctor for your annual comprehensive checkup, would you? Probably not, since that type of doctor can't provide you with a comprehensive evaluation.
• You probably wouldn't go to a veterinarian, since they're experts in other types of mammals, would you? They're just not familiar enough with humans that you'd feel comfortable having them do your annual checkup, right?

Well, if you're sold on the idea that an environmental audit is like an annual medical physical, and you realize there are a lot of benefits to an environmental audit (along with some liabilities), then the inevitable question is:

Who can do the environmental audit, and/or, can I do it myself?

If you followed my checkup analogy above, I think you can tell where we're going with this. That doctor should be an expert, should have a comprehensive understanding of what affects you, and should be familiar with your type of creature, namely a human being.

The person who conducts your environmental audit should have the same qualities: they should be an expert in the environmental field, have a comprehensive understanding of the rules and regulations that apply to you and your type of operation, and should have some degree of knowledge about your type of business or industry.

If you're sold and want a top-notch environmental auditor for your facility, reach out to us here at RMA for a quote! We'd love to explore if we're a good fit for each other.

Is Your Environmental Auditor Biased?

One more thing that an environmental auditor should be is this: independent and unbiased. Ah-ha, that's where the rub with having you or your employees do it comes in!

For example, we've seen lots of situations where we'll start talking to a business owner about environmental audits, and they'll say "yeah, we've done them, I have my environmental person do them".

Okay, would that be the same environmental person who:

• Is responsible for the environmental program and the environmental well-being of the company?
• The one who gets paid to do a great job managing the environmental affairs of the company?
• The one who doesn't want any black marks against their work, such as missing permits or approvals, blown deadlines, missed reporting, bad monitoring results, you name it?

Isn't there a pretty clear conflict of interest here? This type of person can't be expected to be open, honest, and unbiased - it's not human nature to say "turns out I'm doing a bad job"! And what if your environmental manager only knows a certain portion of the regulations, such as being a real expert in air permitting issues, but knowing nothing about EPCRA reporting?

That's not going to work.

The Dangers of Choosing the Wrong Environmental Auditor

So you can see, choosing the wrong person for your environmental audit - whether it's a biased insider, or a less-than-expert consultant - can actually get you in more trouble than if you hadn't audited in the first place!

One way this happens is that you might get lulled into a false sense of security, thinking everything's okay, when in fact it's not. Believe me, we've seen this before. Someone comes in, knows little to nothing about some area of regulations, and leaves the facility thinking they're in great shape.

Next thing you know, along comes an inspector (or worse, a 3rd party lawsuit) who lets the poor business know (via a fine, penalty, or lawsuit) that they're actually not okay - they're in trouble.

Sure, you could possibly go after the auditor, but wouldn't you like to have avoided that in the first place by choosing the right person or firm for the job?

How Can I Tell if an Auditor is Qualified?

Wait a second, a doctor has an MD to prove they know what they're talking about, what does an environmental auditor have? Surely there must be some form of certification or license from the USEPA or the state, right?

Well, not really. There is no broad, comprehensive certification that I am aware of that "proves" that you have what it takes to be an effective environmental auditor, or know enough to do the job right. Some credentials are certainly helpful (such as being an ISO14001 Lead Auditor, or a Certified Environmental Auditor, (both of which I have), but you really have to dig deep to see how directly relevant they are to you, your business, and your environmental auditing needs.

And I hate to confuse you further, but you also need to consider - what type of environmental audit are you seeking? One that is completely comprehensive and covers "everything"? That type of audit requires a different skill set and knowledge level - probably from a team - than does an audit solely focusing on stormwater permit compliance, for instance. So, just because someone can do one type of audit, doesn't necessarily mean that they can do another type of audit.

Here at RMA, we tend to think we're pretty qualified auditors. We've conducted countless audits across a variety of industries for all kinds of different reasons. Reach out to us to see for yourself!

Choosing the Right Environmental Auditor for Your Business

So, I am going to go out on a limb here and say that you probably shouldn't be doing your own audit, since it seems unlikely that whichever insider you choose will be both completely knowledgeable and completely unbiased.

Maybe that person could do audits for you down the road after you've had an initial, top-to-bottom comprehensive environmental audit, but for that first one, I'd say get an external expert (and maybe even consider legal counsel assistance that first time).

If you're going to have to select an external environmental auditor, here's some pointers on what you should look for:

• What do you want? - First, you really need to figure out what type of environmental audit you want, and what you want it for. Are you seeking a full-blow compliance audit, or just an air audit, or an audit to the ISO14001 EMS standards? They are vastly different, and probably mean different auditors.
• Knowledgeable - They need to know the full range of regulations or criteria you're auditing. If you need a stormwater audit, you better hire someone who knows the stormwater regulations in that state forward and backward.
• Professional - This goes without saying. This is a serious job.
• Discrete - You don't want your auditor talking about the results, such as problems found, with their new-found friends at the local bar, now do you? How about with their brother-in-law, the USEPA inspector?
• Credentials - There really aren't any good ones I know of, but go ahead and ask. Have they had auditor training? Do they have any applicable credentials? And don't fall for the old "professional engineer" credential as the end-all-be-all; it would be hard to find many PEs who know the full range of environmental regulations that apply to you (unless that was their area of specialty), although some do.
• Experience - Do you want a rookie, or someone who knows the ropes? Has your auditor done any audits before? And, how well do they know your type of business, the regulations that apply to your business, and the regulations in your state or area? That really matters! If you're a plastics manufacturing firm in the State of Washington, maybe hiring someone from Florida who has only worked in the electrical utility industry might not be the best idea.
• Demeanor - This might not jump out at you, but think of it. Your environmental auditor has to possibly talk to several people at your business, and may be asking difficult, delicate questions. Your auditor should be able to do that without alienating people, offending people, putting them on guard, etc. Talk to your potential auditor; if they can't carry on a civil conversation with you, chances are it's going to be difficult for them when they're walking through your business and talking to employees.
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Wrapping Up: Choosing the Right Environmental Auditor is Crucial!

So there are some thoughts on who can do your environmental audit. As I think you can tell, I'm obviously biased that you should hire an outside environmental expert like us to do your audit, at least the first time a comprehensive audit is done, when you're most likely to find the most glaring problems. If you're in that position, use some of the pointers above. After that, if you want to consider using your inside environmental personnel, then do so at your discretion.

Remember, audits are not just about finding faults; environmental audits are not about finding faults or penalizing businesses; they are about ensuring compliance, improving environmental performance, and fostering sustainable practices. By understanding the true purpose and benefits of environmental audits, businesses can approach them with confidence and see them as valuable tools for achieving long-term environmental and operational success.

Ready to get started? Connect with our seasoned consultants today for top-notch auditing services. Since 1992, we’ve been helping businesses of all sizes across diverse industries achieve compliance, boost sustainability, and foster continuous improvement. Let RMA’s expert team guide you in reaching your environmental goals. Reach out now and see how we can support your success!

Additional Information on Environmental Audits

• What is an Environmental Audit?
• Do I Need an Environmental Audit?
• Preparing for Your First Environmental Audit: What You Need to Know
• The Top 5 Things to Know About Environmental Audits
• The Most Common Audit Findings (and Their Solutions!)
• Environmental Audits: The Checkup that Keeps Your Business Healthy
• Do I Have to Report the Results of an Environmental Audit?
• The True Cost of an Environmental Audit
• Environmental Audits 101 Podcast