TCEQ Auditor Criteria and Third Party Audit Protocol

1. TCEQAuditor CriteriaandThird Party Audit Protocol EMS Stakeholder Meeting April 23, 2003

2. Rule: Auditor Criteria • Independence • Experience • EMS programs • Environmental regulatory programs • Auditing • Education • Certifications granted • Other as required

3. Auditor Certifications • Lead auditor certification • ANSI-RAB • BEAC • IRCA • Others if at least as stringent • Rely on certification bodies

4. Independence • Cannot audit your work • No EMS consulting • Two years prior • Two years future • No EMS development • No EMS software, tools • Financial and managerial independence • Third party only • Different employing company

5. Third Party Audit Framework • As if performed by TCEQ • Individual audit approval • No pre-approval for audits • No approved auditor list

6. Rule: Third Party Audit Protocol • Protocols meet the same requirements as the TCEQ audit protocols • Documentation provides information comparable to TCEQ audit • Method of audit review • Time review of documentation versus field observation and personnel interviews to confirm performance

7. TCEQ Audit Oversight • After Third Party Audit • 20% reaudited by TCEQ • Joint Audit • TCEQ participation • Assure meets TCEQ protocol

8. Third Party/TCEQ Joint Audit • Coordinated audit plan (bid spec) • Multiple objectives • ISO • Responsible Care • TCEQ • Surveillance/Certification • Scope • Sufficient time

9. Audit Protocol • Audit elements for each standard • Documents • Interviews • Observations • Audit decision matrix

10. Aspect Audit Elements

12. Compliance Screen • Cooperate • TCEQ • Compliance History • Other • Third party auditor • EPA

13. Documentation • Pre-assessment • On-site • Review and report

14. Environmental policy Scope of the EMS Prioritized aspects Goals for continuous improvement in environmental performance Goals for ensuring compliance Performance indicators Independent or third-party reviews or certifications Point of contact Regulatory incentives Pre-assessment questionnaire that includes environmental, process, and operational background information Signature certifies true, accurate, and complete Pre-Assessment Documentation

15. Leader Preassessment Docs • Three references stakeholder involvement • Community/citizens groups • Tribal or local regulator • Other community/local reference. • One reference community outreach effort

16. On-Site Documentation • Lead auditor name, contact information, and documentation of EMS-LA certification • Names and contact information of other auditors • Organizational affiliation • Signed certification by the lead auditor and team consulting and independence criteria • Signed certification of senior manager of auditing organization auditing organization financially independent from auditee • Date(s) of audit and audit timeline

17. On-Site Documentation • Facility description • List of people interviewed during the audit • Interview field notes • List of documents reviewed before and during the audit • List of areas observed • Field notes from observation • Justification for any substantial areas not visited • How planned operational changes have been included in EMS

18. Review Documentation • Assessment findings • Lists of non-conformances • Classified by major, moderate, and minor • Described and tied to TCEQ EMS clauses

19. Final Decision • TCEQ decision • Third Party Audit report • TCEQ observations • EPA input for Leader