COVID-19 NEW NORMAL AUDITING
May 19, 2020
BY JEFF MARSHALL
The inherent COVID-19 pandemic dangers require ALL businesses to implement thoughtful institutional controls and unique solutions to operate for the foreseeable future -- commonly referred to as the “New Normal”. While several aspects of day to day business may be temporarily curtailed/suspended, a business cannot properly function without adapting their activities to the New Normal, particularly because the duration of the pandemic is completely unknown. Environmental, Health and Safety and Dangerous Goods Transportation (EHS/DGT) compliance is an essential business aspect that must continually be assessed, managed and maintained less the overall safety and environmental stewardship of a company be jeopardized. There is currently, no blanket protection or deferral of compliance responsibilities in light of the COVID-19 pandemic. Critical to maintaining healthy EHS/DGT compliance is the functioning of a robust, third party auditing/assessment program. GS has developed a broad and flexible set of EHS/DGT auditing solutions that allow businesses to maintain compliance and keep everyone involved safe and healthy.
Third party live auditing, e.g., trained professionals physically touring and observing facility operations, is without question the single most effective method to evaluate EHS/DGT regulatory compliance. During this New Normal, GS is performing EHS audits in the same manner it did prior to the beginning of the COVID-19 crisis, but with added social distancing, PPE requirements, and surveys/temperature-monitoring as facilities require. These audits are as successful as our pre-COVID-19 audits. However, some facilities may not allow these customary audits even with added precautions. They may restrict or limit non-employee visitors - the number, time allowed, meeting practices, logistics, etc. Consequently, these facilities require remote auditing to accomplish their assessments. Remote auditing, while difficult, can be achieved through a planned five-step approach.
Questionnaire
The key to customizing a remote audit begins with understanding the facility’s restrictions, permissions, opportunities, challenges, goals and objectives. GS accomplishes this through a detailed, highly specific pre-audit questionnaire designed to quickly and easily identify these critical details that allow us to propose a high quality, reliable, remote audit approach that most closely resembles our customary audits.
Initial Document Production
EHS/DGT audits can be divided into two major portions: document review and site observations. GS can perform the document review portion of an audit remotely by simply enhancing its current practices of file sharing and document sampling. GS provides facilities with a targeted initial document production based on inputs from the questionnaire that will naturally focus the objectives of the site observation. This is even more critical when the site observations have to be guided remotely.
Remote Site Tour
Conducting site observations remotely can be incredibly challenging without proper planning. Using information gathered from the questionnaire and initial document production the site tour is “mapped” out in advance. Facility personnel then tour the facility at the direction of GS staff using one of several secure “streaming” options. This method is sufficient to conduct conversations and confirm live conditions onsite but requires extremely experienced auditors to understand what is being observed. No checklist, form or procedure can account for variations between facilities – which is why each GS auditor has been in hundreds of manufacturing, retail and heavy industry facilities. The site tour should be supplemented by static pictures to allow auditors to evaluate specific details which are difficult to see in a live streaming format, such as chemicals, complex machinery and field signage/labels.
Post-tour Document Review
The site observations must be supported and confirmed with documentation. Based on the observations in the field GS is able to compile a targeted document production to support the observations made onsite. Trust and verify!
Report
GS communicates audit findings in confidential, concise, detailed observations with direct citation to government rules and regulations. Reports may be generated in any format with or without suggested corrective actions. GS prides itself on delivering reports quickly, often times within 48 hours of the audit completion so facilities can assess and tackle compliance outages while it’s still fresh in everyone’s mind and to minimize interim EHS risk.
If you or organization are interested in EHS auditing solutions during the New Normal, do not hesitate to reach out to Jeff Marshall at GS Consulting: jmarshall@gs-legal.com.