Today, companies face increased transparency demands from shareholders, consumers, and interested parties. A culture of doing the right thing, high integrity, and ethical standards is enhanced by a comprehensive EHS auditing program. It provides assurance to every employee that the company cares about trying to do the right thing, and especially with regard to Environmental, Health and Safety (EHS). A comprehensive EHS auditing program, whether managed internally, externally, or both, communicates that leadership values compliance and corrective actions. Additionally, today's generation of leadership and shareholders has become keenly aware of how environmental stewardship can improve a company's overall performance and provide a competitive advantage with customers in the global economy.

Many corporations are taking a more centralized approach within their governance, risk, and compliance assurance programs, removing the silos that often separated EHS and other corporate regulatory compliance programs. As recently as February 2017, the U.S. Department of Justice Criminal Division updated the guidance on Evaluation of Corporate Compliance Programs1 . One of the key elements of this program, among the 11 total elements, is developing effective methods for prevention, detection, response, and correction of compliance deficiencies. A subsection of this guidance, titled “Continuous Improvement, Periodic Testing, and Reporting,” includes specific questions for prosecuting attorneys to use for evaluation of internal audit practices, and outlines how organizations have used audits to review internal controls, risks, and areas of regulatory compliance to prevent misconduct.

It is clear that effective EHS auditing programs can favorably influence governmental enforcement agencies. Typically, these agencies get involved after an incident occurs and they typically examine actions prior, during, and after the incident or alleged violation. An auditing program that effectively and transparently supports compliance with laws and regulations, is able to demonstrate that the organization has accountability and responds to issues by correcting them in a timely manner.

By routinely engaging external audits, an organization is able to demonstrate that it values policy and procedure evaluation, consistent reporting and disclosure, and implementation of self-governing actions. An external audit can also explore the effectiveness of an internal audit program by using an unbiased, independent audit group. An external audit will examine whether the current internal EHS auditing program is designed to identify compliance risks throughout its functions and locations, and take proactive steps to remedy compliance issues. An organization should consider periodic external audits to ensure that the internal audit program is supporting the organization appropriately, and the issues identified do not occur again. It is important to ensure that the internal EHS audit program is integrated into the overall risk management program for the organization because these types of risks must be included in leadership discussions and decision-making.

Finally, both national and international auditing bodies and standards writing organizations have strengthened the requirements regarding audits of conformance and compliance-including EHS audits, in risk management systems, EHS management systems, and recognized international performance practices.

Trinity regularly supports and augments existing EHS auditing programs, including evaluating recently acquired areas of a business to support their due diligence efforts and evaluating existing, internal audit programs to ensure their effectiveness. Trinity also works with clients in their effort to meet International Organization of Standardization (ISO) and Responsible Care (RC) management system standards as well as support their movement toward public reporting on environmental performance and sustainability programs. For assistance, contact the author at rlarge@trinityconsultants.com.


1 February 8, 2017, “Evaluation of Corporate Compliance Programs”, U.S. Department of Justice, Criminal Division, Fraud Section