PARTNERING IN INDUSTRIAL ENVIRONMENTAL COMPLIANCE AUDITS
|R.F. Chatfield-Taylor, Morrison & Hecker, 2600 Grand Avenue, Kansas City, MO 64108, and M.M. Katzman, P.G. ERM-Rocky Mountain, Inc., 9300 W. 110th Street, Overland Park, KS 66210||
Environmental compliance audits are complex review procedures for a wide range of industrial processes and facilities. The compliance audit requires a multi-discipline approach if systematic, effective, and sustainable results are to be achieved.
However, many industrial clients view compliance audits with distrust: first, unprotected audit results can be obtained by private parties and environmental agencies through the litigation process; and second, there are frequent internal conflicts among specialists conducting the audit. A partnering approach, utilizing environmental consultants, specialist attorneys, and plant personnel is advocated in response to the technical and legal challenges inherent in the audit process.
Partnering is a consensus-building process commonly applied to large projects where differing objectives leads to adversarial relationships between subcontractors. However, as a fact-finding process, partnering between attorneys, independent environmental consultants, and plant or corporate personnel is an effective means for successful conduct of the audit and attainment of audit goals. Successful audits will meet client expectations and/or regulatory objectives when apparently contrasting services can be reconciled within a specific scope of work and partnering agreement.
The partnering concept must be established at the beginning of a project, not when serious problems are encountered. Well-defined partnering plans help to meld the attorney-consultant-corporate team into a coherent unit, each contributing to the team in their own specialty but working together to address site specific challenges. The audit partnering plan must have sufficient flexibility to allow the team to investigate unanticipated conditions that may environmentally, legally, or operationally impact the plant.
This paper briefly reviews the basic concepts of the compliance audit in industrial settings. The audit partnering strategy is analyzed including the legal, operational, and scientific aspects of audit design; selection of audit procedures; the composition of the team; and the functions and obligations of the team members. The benefits and pitfalls of partnering in compliance audits are examined and recent attempts at audit privilege are discussed.
Key words: environmental, audit, compliance, partnering
Return to Main Table of Contents
Sub-Menu of Event Programs
Sub-Menu of Event Programs
Send comments on the Great Plains/Rocky Mountain HSRC web pages to: email@example.com;
comments or questions about this WWW server, to: firstname.lastname@example.org.