Since the start of the COVID-19 pandemic, many organisations have put their Environmental, Health and Safety (EHS) audit programs on hold due to difficulties with physical distancing and potential virus transmission, cash preservation and a desire to eliminate non-essential spending, and the closure of international and domestic borders. However, industry operations continue, and associated EHS risks and compliance obligations remain unchanged in most cases.
Organisations now need to explore options for maintaining their audit programs and evaluate approaches that are most appropriate for their operations. The best method will depend on the objective of the audit. In other words, what is the audit expected to or required to achieve?
The most significant challenge under COVID-19 conditions is the execution of site visits which enables audit evidence to be gathered through observation. This challenge can be overcome as long as the objective of the audit and overall intent of the applicable audit guideline, such as the ISO 19011 Guidelines for Auditing Management Systems, are not compromised and the audit stakeholders agree to a revised methodology.
The following three alternatives for auditing under current pandemic constraints can potentially address your audit needs now and into the future.
1. Remote documentation audit with interviews but no site inspection
A baseline audit can be completed, despite no site inspection, through an in-depth review of site records and interviews with personnel. This type of audit, though limited by auditing standards, would still provide valuable insights into an organisation’s compliance status during shut-down periods or times of fluctuating availability of staff and resources. The emphasis in this approach is on evaluating the ability of the organisation to identify and manage its compliance obligations, rather than on the actual state of compliance at that moment in time.
The advantage of this approach is the ability to verify that baseline EHS programs are continuing effectively, that site-specific regulatory permitting requirements are being met and that evidence of compliance is being maintained by the site. However, without an in-person site inspection, actual EHS site conditions cannot be observed or verified. This approach will not satisfy strict auditing standard requirements but can still demonstrate some level of EHS due diligence over the short term.
2. On-site inspection with remote documentation audit and interviews
Where a site is local and accessible to the auditor, a two-step audit approach is possible. In this combination, the auditor can visit the site to inspect the facility while adhering to COVID-19 personnel protection and distancing protocols, and supplement this on-site inspection by undertaking the documentation audit and interviews remotely, following a similar approach as outlined above.
This approach is likely to meet the general intent of most auditing standards yet will have some limitations due to the auditor self-verifying on-site activities and conditions. In addition, the site tour will be limited to a single visit, which will not allow for follow-up observations as the audit progresses. The impact of this limitation can be managed by touring thoroughly during the single visit, taking detailed notes to support follow-up interviews, and agreeing on the format of appropriate follow-up evidence required to be provided to the auditor following the audit.
3. Virtual site inspection with remote documentation audit and interviews
Technology options are available to support a remote or virtual site inspection of operations. Options vary in complexity from submission of photographs or video recordings (i.e. mobile phones, GoPro®, etc.) to the auditor through to live-stream site tours using mobile, smart glass, or drone technology (i.e., phones / tablets, HoloLens®, Orbit®). These platforms can be initiated and supported by the client or the auditor, depending on in-house IT security protocols. Any virtual tour will need to be followed by a remote documentation audit and interviews as outlined above.
The degree of the auditor’s ability to verify site conditions will depend on the technology used. However, follow-up observations are possible as the audit progresses. The virtual inspection can be optimized by agreeing in advance the detail of areas and activities that should be included. A constraint of this approach is that the images of site conditions shared with the auditor may be left to the discretion of site representatives. There is some potential for staging or intentionally excluding areas, but this can also occur during an onsite inspection. If the mutual audit goal is continuous improvement, this approach can still satisfy the intent of most auditing standards.
Put safety first when planning the audit
No matter which of these audit approaches is used and whatever technology is applied, the health and safety of the audit participants is paramount. COVID-19 protocols must be discussed and mutually agreed prior to any site visit. When taking photographs, recording videos or live streaming within active workspaces, new hazards will result. Complete a risk assessment and establish controls to reduce risks to the photographer or videographer (such as using a spotter/guide, restricting traffic, etc.) and to comply with security protocols.
The audit limitations posed by the COVID-19 outbreak, while unique, are just another set of challenges to overcome and address. With several adaptable and flexible alternative auditing approaches and an array of technological choices, effective auditing can still be possible, even during a pandemic.
Jody McKeown Member Name
Professional Engineer and Certified Environmental Auditor
Dale Haigh Member Name
Senior EHS consultant
Dale Haigh, based in Nottingham, UK, is a Senior EHS consultant with over 30 years environmental, health and safety experience as a consultant and in industry. Dale has led and performed a significant number of audits for regulatory and corporate compliance, due-diligence, certification and environmental, health and safety system purposes on a global basis.