Is Your EHS Audit Program Keeping Up with the Times?

Did you know that U.S. Environmental Protection Agency’s (EPA) issued a new Risk Management Program (RMP) rule in July 2024 to strengthen protections against extremely hazardous substance releases, effecting nearly 12,000 industrial facilities?

In today’s fast-changing regulatory environment, it’s more critical than ever for organizations to ensure their Environmental, Health, and Safety (EHS) audit programs are both up-to-date and thoroughly assessed. Yet, many companies’ EHS audit programs are long overdue for a check-up – some have never even been assessed by external auditors. Whether due to a lack of executive support, insufficient experienced auditors, or simple oversight, failing to review and improve your EHS program can leave you exposed to unnecessary risks.

When was the last time you took a hard look at your organization’s EHS audit program? Here are a few questions to help determine if your program is due for an assessment:

• Is the audit program size and focus “right”?
• Have recent regulatory changes been incorporated?
• Has it evolved with changing operational risks and requirements?
• Does it integrate results from recent risk assessments and audits?
• Are documented audit requirements being followed?
• Does it seek and act on stakeholder feedback?
• Does it benchmark against leading EHS audit programs?
• Has it addressed insights from incident investigations?

If you’re unsure about any of these questions, we recommend assessing your EHS audit program. This article explores the key benefits of EHS audit assessments and how they improve audit effectiveness, efficiency, and value delivery.

1) EHS Audits Identify Operational Risks and Hazards

Companies are increasingly relying on EHS audits to help reduce operational risk. The practices needed to reduce these risks may not be directly required by regulations, rather they have developed and evolved based on the company-specific operating knowledge and risk tolerances.

A strong EHS audit program assessment verifies that activities for risk identification, assessment, mitigation, and monitoring are present and functioning effectively.

For example, in a client assessment, we found that while the audit program checked for risk management practices, it failed to verify whether these covered all operational interfaces. At one site, hazardous material loading and unloading by contractors was considered high risk, but the audit program excluded logistics operations that were performed by contractors.

2) EHS Audits Enhance Regulatory Compliance Assurance

A common deliverable for an individual EHS audit is to verify a facility’s adherence to EHS regulations. By extension, the corresponding deliverable for the EHS audit program is to verify the company’s overall adherence to EHS regulations. A well-executed audit program assessment helps organizations improve the quality of this deliverable by verifying:

• The program’s scope covers all applicable regulatory requirements across operations without duplication.
• It adapts to changes in operations and regulations.
• Audit results are leveraged beyond individual sites to strengthen company-wide compliance.
• Audits are well-documented, use risk-based sampling, and include effective corrective action generation, tracking and verification.

We often see companies lacking a structured approach to applying audit findings across their organization. For example, a company conducts multiple audits, each revealing improper confined space atmospheric testing. Rather than waiting for noncompliance to be found in future audits, the audit program should issue a company-wide corrective action to prevent these deficiencies being found elsewhere, accelerating compliance improvement.

3) EHS Audits Drive Continual Improvement

Leading EHS audit programs continuously refine their approach by integrating stakeholder feedback and adopting emerging audit program “best practices”. Continuous improvement within an EHS audit program ensures better audit outcomes, reduces inefficiencies, and optimizes resource use. Audit program assessments will check what is in place with regard to continual improvement and provide feedback on whether this important system is working.

The COVID-19 pandemic spurred innovation within the audit community regarding remote audit practices. Some audit programs have yet to adopt these practices, however, these techniques have been known to leverage subject matter expertise and reduce travel time and cost.

4) EHS Audits Enhance Decision-Making Through Data-Driven Insights

Increasingly EHS audit programs are incorporating data analytics to gain insights into compliance trends and address root causes, leveraging predictive analytics to anticipate future risks and optimize audit program resource allocation to better examine those risks. By utilizing data-driven approaches, organizations can make informed decisions to help drive long-term efficiency and compliance improvements.

For example, companies shifting from paper-based to digital Management of Change (MOC) systems can analyze the full audit populations instead of samples. Audit programs should develop data queries and train auditors to apply them effectively.

Where to Start with EHS Audits?

Are you ready to assess your audit program and transform it from a reactive compliance measure to a proactive driver of continual improvement? If you’re wondering where to start, check out our webinar, Evaluating EHS Audit Programs, where we share the methodologies and standards that ensure a thorough assessment and how to effectively report findings and strategically address opportunities for improvement.

Let’s Assess Your EHS Audit Program!

Our EHS audit experts have improved the efficiency and impact of EHS audit programs across many industries. Issues identified during audit program evaluations include:

• Audit assurance coverage gaps and redundancies.
• No or limited strategic planning, audit procedures and definitions, quality control, or auditor competency framework.
• Incomplete alignment with audit program stakeholder expectations.
• Insufficient balance between compliance and management systems to deliver audit program vision.
• Overly narrow audit scope that misses broader business risks.
• Weak activity-based or controls-based auditing approaches.

With decades of collective audit experience, our auditors have helped numerous companies remain resilient amid evolving regulatory landscapes by systematically evaluating risks, optimizing processes, and leveraging data-driven insights. We’re here to position you as a leader in corporate responsibility and operational excellence. Contact us today for your EHS audit program assessment.