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Top 10 Audit Issues Don Gansert Managing Consultant February 19, 2009 trinityconsultants.com

Top 10 Audit Issues

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Top 10 Audit Issues. Don Gansert Managing Consultant February 19, 2009. trinityconsultants.com. Multi-Media Audits . Housekeeping Matters The typical compliance issues per media: Air Water Waste Right to Know Risk Management Program Process Safety Management . Air . - PowerPoint PPT Presentation

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Page 1: Top 10 Audit Issues

Top 10 Audit Issues

Don GansertManaging Consultant

February 19, 2009

trinityconsultants.com

Page 2: Top 10 Audit Issues

Multi-Media Audits

Housekeeping Matters The typical compliance issues per media:

Air Water Waste Right to Know Risk Management Program Process Safety Management

Page 3: Top 10 Audit Issues

Air Non-compliance with operating and construction permit requirements

Monthly emissions calculations missing i.e. tracking VOC emissions on a 12-month rolling average

Pollution control equipment – operating & maintenance logs missing Emissions calculations missing for new equipment not permitted Construction and operating permit applications signed by someone other than

the responsible official Operating permit applications submitted late

Less than six months from expiration date or past the expiration date CFC or HCFC chemicals

Leak rate calculations missing 3 years of service records missing Training certificates of contractors missing

Asbestos Record of agency notification for demolition projects missing

Semi-annual deviation and monitoring reports missing or late Annual Compliance Certification Report signed by someone other than the

responsible official or submitted late

Page 4: Top 10 Audit Issues

Water

NPDES permits Storm water pollution prevention

plans Spill prevention control and

countermearsure plan

Page 5: Top 10 Audit Issues

NPDES Permits

DMR reports Reports periodically submitted late Lack of timely verbal and written notification for exceedances Action plan missing for a pollutant(s) exceeding a limit on a periodic bases Reports signed by someone other than the responsible official

Testing pH test results not performed immediately pH buffers out dated Chlorine test results not performed immediately

Permit applications Signed by someone other than the responsible official Do not reflect actual backup water system(s) discharged to surface waters

Many city water systems contain chlorine Non permitted discharges not captured

Facility discharge from A/C units or air compressor blow down

Page 6: Top 10 Audit Issues

Storm Water Construction

Construction permit applications missing New construction impact area greater than 1 acre, not including the

storage pile, contractor parking, temporary drive ways If construction permit issued, the following items missing:

Training records of contractors, truck drivers, etc. who will pass through area

Periodic inspection records missing Inspection records do not reflect the condition of the area inspected Silt fences missing or damaged Site map not kept up to date as the location of erosion controls change The plan is not readily available for review Erosion evident and not controlled

Permit application signed by someone other than the responsible official

Notice of Termination (NOT) missing even though project completed more than a year ago

Page 7: Top 10 Audit Issues

SPCC

Documentation of the facility-wide oil storage capacity for the facility missing

Facility contacts not updated Agency contact list not updated Containers with a capacity of 55-gallons missing

i.e. Maintenance shop drums of lube oil, motor oil, used oil Operational equipment with a capacity of 55-gallons or more missing

i.e. Oil-filled electrical transformers, hydraulic equipment on presses, etc. Site map

Overhead piping and loading/unloading areas missing 55-gallon drums, full, partially full and empty missing

Inspection records Signature of the inspector (usually see initials) 3 years of inspection records incomplete or missing

Substantial Harm Determination Certification missing

Page 8: Top 10 Audit Issues

Waste Hazardous Waste

Satellite containers Bungs loose Containers not closed Containers missing hazardous waste label

Less than 90 day storage area 3 years of weekly inspection records incomplete or missing Bungs loose on drums Date missing

Manifests not legible on all copies &/or incomplete Training

Type and amount of training information missing in the employees file Training records older than 3 years missing

Job Description Job description of hazardous waste duties missing, the amount and

type of initial and annual training Universal Waste

Training records missing Proper container labeling missing Date on container missing Container not closed

Page 9: Top 10 Audit Issues

Right to Know Tier II

Chemical inventory missing Threshold determination missing

i.e. during walk thru, discovered chemicals exceeding 10,000 lbs not on the Tier II

Extremely Hazardous Substances (EHS) in mixtures not totaled and compared to the threshold planning quantity (TPQ)

A new EHS added to the Tier II but an initial notification report missing The incorrect number of days on site carried over from previous years

i.e. in 2006, new chemical (A) brought on site for 279 days. The 279 days is carried over and reported in the 2007 and 2008 reports.

Storage areas and type of container change but not updated on the site map

Toxic Release Inventory (TRI) Threshold determination(s) missing Air emissions calculations used are different than the calculations used

for the annual air emissions report The calculations used to determine the release to each media missing or

incomplete The annual reports for the past three years missing

Page 10: Top 10 Audit Issues

RMP (Risk Management Program) Evaluating program level Review, update, and certify sections of RMProgram Report most recent dates of:

Hazard review (Program 2) Required to review, and document, every 5 yrs

Process Hazard Analysis (Program 3) Operating procedure training

Refresher training every three years Required to certify annually that current and accurate

(Program 3) Compliance audits

Required to audit every three years Maintenance/Mechanical Integrity Program Review Management of Change Review (Program 3) Emergency Response Program Training

5 year review of RMP Plan Online Submittal - RMP*eSubmit (available soon)

Page 11: Top 10 Audit Issues

PSM Each process hazard analysis (PHA) not updated and revalidated at

least every five years Team findings and recommendations not promptly addressed,

resolved in a timely manner and documented Operating procedures are not developed or incomplete for every

process Training

New employees or transferred employees not provided initial process safety management training

Records showing the date of training missing Means to verify employee understanding lacking Contractor training verification missing

Pre-Startup Safety Reviews for new and modified facility records incomplete

Inspection records incomplete Incident investigation records incomplete

Form not completed Five years of incidents missing

Hot Work Permits not completed Compliance audits not performed at least every three years

Page 12: Top 10 Audit Issues

Questions?