Presentation and Schedule of the Module 5 Emas internal audit and Verification

1. Presentation and Schedule of the Module 5Emas internal audit and Verification

2. Agenda of the first day • Presentation of the module 9.00 – 9.15 • Presentation of the participants 9.15 – 9.30 • Elements and requirements regarding environmental audits 9.30 – 11.00 • Break 11.00-11.10 • Elements and requirements regarding environmental audits 11.10 – 13.00 • Role playing: to prepare a check list and to correct it all together 14.00-17.30 (Break 16.30-16.40) • Feedback of the day 17.30-18.00

3. Agenda of the second day • Competence of Environmental Management System internal auditors 9.00 – 11.00 • Break 11.00-11.10 • Test of the First Training Unit (to give test and to correct it with the participants) 11.10 – 12.10 • Definitions, Elements and requirements concerning the Environmental Audit after Emas regulation 12.10 – 13.00 • Definitions, Elements and requirements concerning the Environmental Audit after Emas regulation 14.00-17.30 (Break 16.30-16.40) • Feedback of the day 17.30-18.00

4. Agenda of the third day • Definitions, Elements and requirements concerning the Environmental Audit after Emas regulation 9.00 – 11.00 • Break 11.00-11.10 • Role playing:to simulate an Environmental Audit after Emas regulation 11.10 – 13.00 • Competence for internal auditors after Emas Regulation 14.00-16.30 • Break 16.30 – 16.40 • Test of the Second Training Unit (to give test and to correct it with the participants) 16.40 – 17.30 • Feedback of the module 17.30-18.00

5. Presentation of the module This module has to assure the following competencies : • Conduction of an internal audit or verification • Examine the conformity with all Emas requisites

6. This project has been funded with support from the European Commission. This publicationreflects the views only of the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.

7. Elements and requirements regarding environmental audits Chapter 1

8. Audits carried out in an Organisation, (they can be of the 1st, 2nd or 3rd party), have as a main scope judgement, through samplemethod, of the conformity of the implemented management system with the established requirements. The definition of the audit given in UNI EN ISO 19011 Ed. 2003, helps to understand better the meaning of an audit : “Systematic process, independent and documented for obtaining audit evidence and evaluate objectively, in order to establish to what extent are audit criteria met”. Scope of the audit

9. Detailed knowledge of the extension of the audit is an imperative condition for the preparation of an effective and efficient audit, tightly connected to the objectives established by the audit itself. Verification group, also called audit team, should always have a person in charge who is assigned a role of guidance and reporting. In addition to this role, the team may also be composed of other figures identified as: evaluator (auditor), technical expert, and observer. Extension - Cycles and frequencies - Components of the audit team

10. UNI EN ISO 19011 ed. 2003 defines an auditor as: “A person that has competence to carry out an audit” The competence, in fact, is also a function of the type of audit that a person is about to perform, both for type, of the first and second party, and for ambit, quality (QMS), environment (EMS) or security (SMS). Auditor

11. To achieve confidential knowledge of the conformity of the applied system by the organisation that is object of evaluation, respecting the environment and conformity legislation Objectives of an Audit

12. Internal audits (or first party) carried out with the aim of verification of the accomplishment and effectiveness of the EMS or some important aspects, like: particular production processes, products and services, departments or functions of the company. External audit (second party) audits carried out by an organisation on its supplier (Client-Supplier relationship) using, in this case too, either internal personnel, usually an interfunctional team, or external society is entrusted with doing it. Certification audit (third party) independent of the EMS of a company, that have as an aim release of the certificate of conformity with the requirements taken as a reference, that may be ISO 14001 Standards:Edition 2004 or the EMAS Regulation. Types of Audit

13. first party or internal visits: they are programmed and completed within pre-established periods; second party visits (on the part of the client to the supplier): there may be deadlines based on the needs of the supply contract; third party visits (on the part of the certification body to the organisation): repeated every three years, this is the case of re-certification, but at intervals, during the period in which the certificate is valid, there are annual or semi annual surveillance audits. Audit Programme – Kind of visits

14. It is a good practice to issue an audit programme based on agreed frequencies. first party audit: the audit cycle is in relation to the necessity to furnish objective information about the conformity of the EMS with the plans in order to respond to the requirements of the reference standards. The complete results have to be available for the Top Management so that it can take corrective and/or improvement actions; second party audit: the audit cycle is determined by the existing contract or by the contract that shall be defined in the purchase order. In fact, the audit cycle is often connected to the supply and/or supplier qualification cycle. Therefore, once it is finished, there is no need to prolong audits; Audit programme and frequency - 1

15. third party audits: the audit cycle is in function of the validity of the certificate, in fact, within that period, the audit cycle has to be completed in order to guarantee that, at least once, all the EMS has been reviewed after the certification audit result. Audit programme and frequency - 2

16. An activity shall undergo an audit during the entire cycle, the audit frequency and in general it is connected to the following factors: the nature of the organisation’s effectiveness in terms of environmental aspects and potential impacts; the number, the importance, the complexity, the analogy and the localization of the activity to be audited; the standards, the laws, the regulated requirements and their development, contractual requirements and other applicable criteria; the necessity of accreditation, certification, qualification and requalification; Audit frequency for an activity with the reference to its characteristics - 1

17. the introduction of the modifications to the EMS or to one part of the process of the realization of a product/service; the conclusions of previous audits or the review of the previous audit cycle; the communications of the competent authorities and/or the complaints of the interested parties; the language, cultural and social aspects Audit frequency for an activity with the reference to its characteristics - 2

18. to decide who shall carry out the audit (including also possible figures like experts, for example for technical or legislative sector); to identify the standard or requirements to satisfy (e.g. supply contract, manual, procedures, actual environmental legislation both on national and regional/local level); to inform the person in charge of the reality to be audited (auditee) of the scope of the audit, reference standards and the demand to put at disposal every instrument or guide that may be necessary; to establish a date convenient for both parties; to gather as much information and data about the organisation as possible using, for example, the institutions or navigating through web sites that are often used by companies as a marketing or promotion instrument; to identify the Lead auditor. Audit Programme - Contents

19. In case of the audit for obtaining the certification, third party visits, it is necessary to perform a visit, so called pre-audit or stage N.1, that comes before the one for the issue of a certificate, initial audit or stage N.2. (The pre-audit is an obligatory phase for issue of a certificate but also a necessity, that is useful when focalising the aspects given here, from the point of view a more aimed and efficacious audit for certification). Audit Programme – Pre-Audit

20. The extension of an audit is connected to different aspects like size, nature and complexity of the site to be audited Extension of the audit

21. Number of audits to carry out in an organisation, linked to: the scope of the audit to verify conformity of the elements of the EMS with the prescriptions ; to verify effectiveness of the EMS put in practice in order to achieve objectives fixed in advance; to provide an organisation with some hints for improvement of its EMS; to fulfil specific contractual prescriptions; to certify the EMS of an organisation. Numerousness of the Audits

22. Client of the audit: an organisation or a person commissioning the audit Subject of the audit: an organisation that undergoes an audit (auditee) Certification body: an independent organisation approved and charged with carrying out third party audits of the standards recognized both on national and international level. Can also carry out second party audits Audit team: it is composed of one or more auditors that carry out an audit and are supported, if necessary, by technical experts Certifier (environmental): an auditor acknowledged by a certification body Auditor (environmental): a person qualified to carry out an environmental audit Technical expert: a person who provides knowledge or specific competences to the audit team. Roles and characteristics of all involved subjects

23. Audit has to be based on objective evidence. They have to be seen as a testimonial with the aim of evaluating at least the following aspects of Environmental Management system: system performances necessities that the system has to realize strong points of the system weak points of the system. Audit of actual data for evaluation of environmental performances

24. Principles and criteria that will have to be respected by each component of the team are: Ethical behaviour: the basis of professionalism Impartial performance: an obligation to report truthfully and precisely Appropriate professionalism: application of accuracy and perception on audit Independence: the basis of impartiality of the audit and objectivity of its conclusions Approach based on evidence: rational way of achieving reproducible conclusions of a systematic audit process. Behavior of an auditor

25. Beginning of an audit Management of the documentation review On-site preparation of the audit Carrying out of the audit on-site Preparation, approval and distribution audit report Closure of the audit Realization of the actions following the audit. The steps of an audit

26. To appoint the audit leader To define audit objectives To determine the feasibility of the audit To select the audit team To establish the initial contact with the auditee (ISO 19011:2002) Beginning of an audit

27. determination of the level of conformity of the EMS being audited, or parts of that system, with the audit criteria, evaluation of the capability of the EMS to assure the conformity with the coercive and contractual requirements, including the willingness of the interested parties; to give a judgement about the effectiveness of the EMS in obtaining specified objectives and pursuing them with the improvement plans; to point out the areas and processes sensible to a potential improvement Audit objectives

28. Documentation that has to be analysed during the audit Manual and Procedures of the EMS (internal) Analysis and Environmental evaluation (internal) Lay-out (planimetry/ water circuit) effluent discharge waters (internal/external) Plant planimetry including the points of emission (internal/external) Authorisations from the authorities in charge, like Province, the Fire Brigade, and other public subjects (external) Registrations of the instruments calibration (internal/external) Reports of the previous audits (internal/external) Communication between interested parties (external) Purchase contract (external) Environmental quality reports regarding the production site (external) ………. DOCUMENTATION REVIEW

29. Preparing the audit plan Assigning work to the audit team Preparing work documents ON SITE PREPARATION

30. This document represents, in general, formalization of the visit carried out at the organisation. In it, the personnel of the organisation may find different information Audit plan (Itinerary)

31. guidelines (production areas); check lists (for desk study or on-site activities); digital camera. Instruments for carrying out an audit

32. They are technical documents for the sector, very useful in terms of suggestions and planning, regarding compliance with the “normative requirement” analysed. These documents are available at Italian national standards institute (UNI) or they are part of the internal documentation elaborated by an Accreditation of Certification body, in the latter case the document expresses the point of view of the body that is author of the guidelines. Guidelines

33. Check-lists deserve a particular hint, can be used as an instrument assistance and registration during different phases of the audit and may be elaborated respectively in the following phases: documentation review; preliminary visit (certification visit); on-site visit (1st, 2nd, 3rd party); maintenance/surveillance visit. Check lists or control lists - 1

34. The check list is in fact a questionnaire that should cover all the points regarding the reference documentation, according to the type of audit being carried out (certification standard, supply contract, manual, procedures, etc …). The questions in the list should be: of confirmation. The procedure of operative control is in order and use. The involved personnel knows it. of control. Take a significant sample of activity. Proof and/or surveillance (e.g. registration of the report of the test of the fire-prevention system or of an analysis of the refluent waters before they are introduced into public waste waters). Check lists or control lists - 2

35. It has, however, a big effect and it is at the same time explanatory, to support exposure of the results at the end of the audit with the help of this instrument, for example during the final meeting or in the audit report enclosing the photos. It is right to clarify that this instrument has to be used only as a support and cannot substitute well established techniques and methodologies for carrying out an audit. Digital camera

36. Opening Meeting is the first formal encounter between the audit team and the company, it is possible to use a check-list with the topics to be treated Introduction List of participants Presentation of the audit team Place for meetings – logistics Objectives of the audit Reference standards and the relevant EMS documentation Identification of the organisation’s representatives Carrying out – Opening Meeting

37. Identification of the company’s personnel that have the role of companions Explanation of the methods of enquiry, such as significant aspects and sampling methodology, and the final ones, of evaluation by the audit team, such as demands for corrective actions, recommendations, etc… Refinement of the audit programme with the relevant modifications Reconfirmation of the time scheme for the final meeting Modalities of presentation of the final report Modalities of organisation’s answers Privacy guarantee Carrying out– Opening Meeting

38. During the interview in practice, the component of the team is supported, in his evaluation, by the following aspects: analysis of the documentation available for the personnel (environmental analysis, operative control procedures, work instructions, etc….); discussions with directly interested person; analysis of how an activity is carried out; existence of equipment and facilities; registrations produced on prepared forms Gathering the evidence (enquiry) and interviews - 1

39. Search for objective evidence, during all the audit, should be directed towards following objectives: to have a proof of the correct implementation of legal and organisation’s prescriptions to have the proof of the comprehension of the EMS and awareness of the impacts that the activities may have if not carried out correctly to have the proof of adequacy of the human and material resources to have the proof of the effectiveness of the EMS (surveillance and measurements) to find interrelation with different processes of the organisation to verify the activities and results obtained through continuous improvement attempts in all management system processes. Gathering the evidence (enquiry) and interviews - 2

40. The whole audit activity should be summarized findings or possibilities of improvement, such as recommendations or observations. They are usually potential situations that might be improved or those that might lead to a nonconformity unless resolved. Findings

41. The technical term that is generally widely used to describe the finding is Request for Corrective Action (RCA), that can be divided into major or minor, first or second category, and according to other classification. Sometimes, instead of previous definition, (RCA) a term Non Conformity (NC) can be found. From a formal point of view, the result of a private meeting is identified with issuing of some documents within predisposed forms. In general, the following forms are always present: Requests for corrective actions Final report Request for Corrective Action and Non Conformity

42. Features: step that concludes the course of audit that started with the phase of documentation review; moment during which conclusions and judgement of the audit team are exposed to the organisation’s management; has to be presided by the Lead Auditor, whose task is to represent and expose the evaluation of the audit team; the lead auditor can use a check-list where all topics that are to be treated are listed; leaving the type of audit apart, the phase of results presentation should be managed professionally by all members of the team, avoiding to express spontaneously opinion on significance of the findings and the behaviour of the interviewed personnel. Closing meeting

43. The audit report is a document that formally reports what has been exposed during the closing meeting, it has the following caractheristics: signed by the Lead Auditor clear and concise presentation of the contents in order to make comprehension easier and for later use of the document, as a reference for afterward enquiries that may be conducted by a different team complete, accurate and clear registration of the contents of the audit, since the aim is to inform the commitement of the “status” of EMS implementation against the established criteria Audit report (results, evidence, conclusions)

44. Widespread term used to indicate the activities to be implemented, afterwards a negative result obtained during the first audit (internal/external), or at the end of the surveillance/maintenance audit. Activity is preceded by the issue of a reaction plan by the organisation that was audited. Management of the RCA is quite similar in different audit situations and it follows the course of problem identification, proposal of a solution, approval and implementation of the proposal, verification of the solution and, in the end, verification of the effectiveness. Modalities of the audit of RCA/NC is function of the seriousness of the problem discovered and the “status” of the EMS Follow-up audit

45. Competences of Environmental Management System internal auditors Chapter 2

46. Auditors are not improvised figures, but, on the contrary, they must have appropriate preparation based first of all, but not only, on the following aspects: personal characteristics; character predisposition; technical knowledge and acquired experience. Auditors

47. ISO 19011:2002 Standard, related to the personal characteristics of a typical auditor, says that tha auditor has to: respect standards of professional practice, be polite, sincere, honest and be not insistent when asking questions; be open minded, willing to take into consideration alternative ideas or different points of view; be diplomatic, treat people in a correct way (know how to conduct an interview and relationships both with the personnel of the organisation and with other members of the audit team); a careful observer, participate actively in what surrounds him and the activities taking place in his presence; Personal Characteristics - 1

48. demonstrate to be quite perceptive, be instinctively involved and be able to understand different situations that may happen during the audit; be versatile and able to manage any unexpected situation, acting immediately; be tenacious, persistent, determined and directed towards reaching objectives; demonstrate the ability to take decisions, reaching quickly conclusions based on logical analysis and reasoning; demonstrate to have a sense of self-control, be always active and independent from other people, and be always involved in what is happening within the audit. Personal Characteristics - 2

49. ISO 19011:2002, says: Area N.1: Principles, procedures and techniques of audit: in order to have the ability to distinguish, one by one argument, parts that are appropriate for the audit to be carried out. Area N.2: Management System and Reference Documents: in order to consent the auditor comprehension of the audit area and to apply the criteria. Area N.3: Organizational Situations: to consent the auditor the comprehension of the operational context of the organisation. Area N.4: Applicable laws, regulations and other requirements regarding the discipline: to consent the auditor to do his activities and be aware of the requirements that are applied to the organisation where the audit is to be carried out. Knowledge and competence

50. The team leader should have other competence in addition compared to other components of the team. In fact, the lead auditor should be able to: plan the audit and use efficacious resources during the audit; represent the audit team in relations with the audit client and the organisation object of the audit; organize and guide the members of the audit team; manage and guide auditors-in-training; guide the audit team to achievement of the audit conclusions; prevent and resolve conflicts; prepare and complete audit report. General knowledge and competence for Lead auditors