Audit Process and Approach

Confidentiality.  As a law firm, GS protects its clients to the greatest extent possible through the attorney-client privilege and attorney work product doctrine.  All field notes and reports are marked with appropriate confidentiality statements and environmental audit privilege language.

A Pre-Audit Questionnaire.  This questionnaire requests basic information about facility EHS activities.  It also requests certain documents prior to the audit to enable the auditors to:
• understand the facility’s legal and permit requirements, written programs and plans, and operations prior to the audit,
• become familiar with the facility,
• understand reporting and recordkeeping formats used by the facility,
• reduce travel expenses for the facility by auditing certain documents off-site, and
• reduce interference with site personnel and operations by completing some of the audit away form site activities.

An Opening Meeting.  The opening meeting introduces the auditors and facility staff. It is designed to describe the process and ensure that all expectations are understood and will be met during the audit.  This meeting requires 15 – 30 minutes and is usually attended by the plant manager, and EHS staff, and any other personnel deemed necessary to the audit process.

A Table-Top Review.  After the opening meeting, facility EHS staff briefly review manufacturing and ancillary operations through the use of facility drawings.  This review usually lasts 15 - 30 minutes.

A Facility Tour.  Facility personnel lead the auditors through the facility, ancillary operations, and outside the facility, so they can observe equipment, operations, and practices.  This tour typically requires one-half to one day.  Interviews may be conducted during the tour.  During the site visit, GS’s auditors typically discuss their thoughts openly to keep facility personnel apprised of possible deficiencies, conditions, and observations.  GS does all it can to avoid unpleasant surprises.

Document Review.  After the site tour is completed, the auditors review required EHS documents; permits, plans, monitoring and inspection records, and required reports.  During this part of the audit, we typically list documents on a white board or easel and check them off after they are provided.

End-of-Day Meetings.  At the end of each day, GS’s auditors provide an update as to deficiencies (findings), concerns (potential problems), and observations.  We do this to ensure that the facts are correct, to bolster everyone’s understanding of the issues, to avoid surprises, and to provide the best opportunity for facility personnel to provide available documents and discussions that might refute or correct our concerns.

Closing Meeting.  A closing meeting will be held to summarize the primary findings, and to provide facility management with an overall conclusion about the audit.  This meeting normally takes about 30 minutes and is typically attended by the same people who attended the opening meeting.

Audit Report.  GS is known for prompt reporting.  We strive to provide the audit report before leaving the facility on the last day, or within one day of the audit.  GS will follow the reporting format described in the Request for Proposal.