Environmental, Health and Safety Auditing
This domain tests whether a candidate can apply audit principles to EHS compliance and management-system performance. Expect questions on defining audit scope and criteria, selecting permits, regulations, ISO 14001/45001 clauses, and internal procedures as requirements, gathering and weighing evidence, classifying findings, and following up corrective action. The exam stresses professional judgment: every finding must be traceable to a criterion and supported by sufficient, reliable evidence.
Core rules and concepts
- Use the criteria–evidence–finding chain: state the requirement before judging the condition.
- Triangulate evidence across records, interviews, and observation. A policy document alone or one interview is weak evidence.
- Sample deliberately by risk, materiality, prior findings, and recent change; record sample size and rationale.
- Distinguish nonconformity from observation or opportunity for improvement. Do not inflate observations into nonconformities.
- Protect independence and objectivity; do not audit your own work or consult and audit the same activity.
- EHS-specific evidence includes permit limits and monitoring, emissions and waste records, training, exposure monitoring, PPE, incident investigations, the legal register, and management review.
Worked example
An auditor reviews a hazardous-waste accumulation area at a facility generating 1,400 kg/month of non-acute hazardous waste. Generation records show large-quantity generator status. The criteria are the RCRA large-quantity generator accumulation standard and the facility procedure. Sampling 12 drums, the auditor finds three without an accumulation start date and an inspection log missing two of 13 weeks. The auditor triangulates generation records, drum labels, inspection logs, and an interview with the waste handler. Finding: nonconformity - the facility cannot demonstrate the 90-day accumulation limit for three containers, and weekly inspections were not documented. This is not an opportunity for improvement because required records are absent. Corrective action: label containers at point of generation, use a weekly checklist, and add supervisor verification. Follow-up: re-audit after 30 days.
Traps that cost marks
- Writing a finding without citing the specific criterion.
- Treating a single observation as a systemic nonconformity.
- Letting the auditee choose samples or interviewees.
- Confusing a compliance audit with a management-system audit.
- Closing corrective action on a paper response without effectiveness evidence.