TCEQ Auditor Criteria and Third Party Audit Protocol EMS Stakeholder Meeting April 23, 2003

Rule: Auditor Criteria  Independence  Experience –EMS programs –Environmental regulatory programs –Auditing  Education  Certifications granted  Other as required

Auditor Certifications  Lead auditor certification –ANSI-RAB –BEAC –IRCA –Others if at least as stringent  Rely on certification bodies

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

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

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

TCEQ Audit Oversight  After Third Party Audit –20% reaudited by TCEQ  Joint Audit –TCEQ participation –Assure meets TCEQ protocol

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

Audit Protocol  Audit elements for each standard –Documents –Interviews –Observations  Audit decision matrix

Aspect Audit Elements

Compliance Screen  Cooperate –TCEQ Compliance History Other –Third party auditor –EPA

Documentation  Pre-assessment  On-site  Review and report

Pre-Assessment Documentation  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

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

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

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

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

Final Decision  TCEQ decision  Third Party Audit report  TCEQ observations  EPA input for Leader