INTRODUCTION

Audits of Environmental, Health and Safety (EHS) performance have been widely used in industry since the early 1980's. The focus of most of these EHS audits has been to determine compliance with applicable regulatory requirements, and have, therefore, been largely driven by legal liability concerns. In a time period of rapidly escalating regulatory oversight and multi-million dollar fines, corporate management was concerned about EHS performance primarily from a defensive viewpoint - "Are there any significant, unknown risks which may impact the profitability of the enterprise?"

The emphasis on compliance performance influenced the design of audit tools. In general, compliance audits tended to be of a "checklist" nature, and the results of the assessment tended to be binary - an operation was either "in compliance" or not. The primary output of the audits were the "findings"; those regulatory requirements for which the entity was "not in compliance". Because the audits were often considered legal documents (most were conducted under direction of an attorney), the results were not widely disseminated and communicated, based on fear of legal action by regulatory and other groups. The follow-up process tended to be somewhat punitive in nature, driven by corporate level oversight - the audited operation was left with a list of items to "correct" - that is, to achieve compliance.

In many cases, this audit process was successful in achieving its primary goal - improvement in regulatory compliance. Particularly in cases where the audit process was implemented as a continuing, long term strategy in conjunction with other EHS management initiatives, such as program development and training, performance improvements have been substantial. However, many organizations are now experiencing diminishing returns on their investment in the traditional audit approach. There are several reasons for this effect:

  • The goal of the audit - regulatory compliance - is a finite endpoint. As facilities come closer to the goal, the opportunities for improvement tend to diminish.

  • It was not always clear that the effort focused on "compliance" was always the most productive use of resources. In some cases, the audit findings demanded management time and budget that could be more effectively applied to other EHS priorities.

  • The audited organization "learns" over time how to score well on an audit. In a classic "Pavlovian" response, most organizations change their behavior to enhance the chances for reward. They learn how to prepare for an audit by understanding the particular nuances of the audit instrument, as well as the biases and preferences of the audit team. No audited organization ever hurt its performance assessment by catering to the culinary inclinations of the audit team.

The Continuous Improvement Concept Applied to EHS Performance Assessment

Many organizations are currently re-evaluating their EHS Audit processes in order to achieve greater value and open the opportunity for further improvement in EHS performance. As implied by the above discussion, the concept of "continuous improvement" was not a primary motivator in the design of most traditional EHS audit processes - although improvement was a goal, it was defensive in nature.

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