Kiểm toán môi trường - Báo cáo tài chính | Đại học Thái Nguyên

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THAI NGUYEN UNIVERSITY OF ECONOMICS AND BUSSINESS ADMINISTRATION
INSTITUTE OF INTERNATIONAL EDUCATION
INTERNAL AUDIT AND OPERATION AUDIT
Topic: Environmental Audit
Student group’s name: Pham Thuy Duong
ID Student: DTE2053403010766 Class: K17 KTTH CLC
Instructor: Nguyễn Thị Phương Thảo
THAI NGUYEN, 2024 lOMoAR cPSD| 46560390 lOMoAR cPSD| 46560390 TABLE OF CONTENT
OBJECTIVE OF TOPIC.................................................................................III
CONTENTS.........................................................................................................1
CHAPTER 1. OVERVIEW OF ENVIRONMENTAL AUDITS....................1
1.1. ORIGINS OF ENVIRONMENTAL AUDITING...................................................1
1.2. OBJECTIVES AND SCOPE OF ENVIRONMENTAL AUDITING...........................1
1.2.1. Objectives of Environmental Auditing..................................................1
1.2.2. Scope of the Audit.................................................................................2
1.3. IDEAS AND FUNCTIONS OF ENVIRONMENTAL AUDIT...................................4
1.3.1. Benefits Derived from Environmental Auditing...................................4
1.3.2. Functions of Environmental Audit........................................................4
1.4. THE ESSENTIALS OF AN ENVIRONMENTAL AUDIT........................................5
1.4.1. Full commitment from management:....................................................5
1.4.2 Objectivity of the audit team:................................................................5
1.4.3 Professional capacity:...........................................................................6
1.4.4 Cooperation of audited facility staff:....................................................6
1.4.5 Systematic and clearly defined procedures:..........................................6
1.4.6 Audit report:..........................................................................................6
1.4.7 Quality assurance:.................................................................................6
1.4.8 Post-audit activities:..............................................................................6
1.5. CONTENTS OF ENVIRONMENTAL AUDIT......................................................7
1.6. TYPES OF AUDIT AND TYPES OF ENVIRONMENTAL AUDIT...........................8
1.6.1. Legal audit............................................................................................8
1.6.2. Technical audit.....................................................................................8
1.6.3 Waste audit............................................................................................9
1.7. ENVIRONMENTAL AUDIT - A COMPONENT OF AN ENVIRONMENTAL
MANAGEMENT SYSTEM.....................................................................................10
1.7.1 Environmental Management System (EMS)........................................10
a, Purpose of Environmental Management System:.................................10 b,
Components:.........................................................................................10 c,
Standards:..............................................................................................11 d,
Benefits:................................................................................................11 e,
Integration with Other Management Systems:......................................11
1.7.2 Environmental audit - A component of an environmental management
system...........................................................................................................11
1.7.3 Role of Environmental audit within EMS............................................13
1.8. THE RELATIONSHIP BETWEEN ENVIRONMENTAL AUDIT AND SOME OTHER
INSTRUMENTS...................................................................................................14
1.9. APPLICABLE STANDARDS FOR ENVIRONMENTAL AUDIT...........................17
1.10. INTERNATIONAL AGENCIES INVOLVED IN ENVIRONMENTAL INSPECTION i
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..........................................................................................................................20
1.10.1. Professional environmental auditing agencies................................20
1.10.2. Non-specialized agencies participating in environmental auditing.20
1.11. PERFORM ENVIRONMENTAL AUDITS IN THE WORLD AND IN VIETNAM...21
1.11.1. Current Status of Environmental Auditing Worldwide....................21
1.11.2 Perform environmental audits in Vietnam........................................24
CHAPTER 2. BASIC STEPS IN ENVIRONMENTAL AUDITING...........27
2.1 PRE-AUDIT ACTIVITIES OR PREPARATORY ACTIVITIES...............................27
2.2 FACILITY AUDIT ACTIVITIES.......................................................................28
2.3 POST-AUDIT ACTIVITIES.............................................................................29
2.4 EXTENDING THE AUDIT PROCESS—OTHER TYPES OF AUDIT...................29
QUESTION........................................................................................................31
TERMINOLOGIES..........................................................................................33
CONCLUSION..................................................................................................35
REFERENCES..................................................................................................36 ii
Lớp: K17-KTTH-CLC lOMoAR cPSD| 46560390 OBJECTIVE OF TOPIC
Since previous decades, concern for the environment has been increasing, and
environmental issues have also exerted pressure on businesses. These pressures
are mainly concentrated on industries that are major sources of pollution.
Environmental auditing was born in this context, in the 1970s in North American
countries. Initially, environmental audit was considered a sharp and effective tool
in the internal environmental management system of companies, as well as a
powerful tool to help environmental managers prevent and minimize pollution
and environmental risks, and improve the environment. Its aim is to evaluate
compliance with laws and regulations determined about the environment, assess
environmental risks created from the activities of facilities producing products,
and evaluate the effectiveness of the management system. Since the late 1980s,
environmental audits have become a popular tool in many developed countries,
widely applied in industry and commerce in developing countries, especially
since the International Standards Organization (ISO) issued the ISO 14000
environmental management system standard. With regulations on environmental
auditing, it has gained a certain international position.
Nowadays, the principles of environmental auditing are no longer just performed
for industrial activities. There are more and more schemes related to the
application of these principles for different programs in communities, agencies,
hospitals, and schools due to the diverse benefits and objectives of environmental
auditing. In addition to the aforementioned goals of environmental auditing,
although there are no regulations intended to be mandatory, it is now possible to
consider the final stage of environmental impact assessment (EIA) to check the
accuracy of operational forecasts stated in the EIA report after the project has been
implemented or officially put into operation for a period of time. In Vietnam,
environmental audit is still a relatively new concept but has also received a lot of
attention in recent years. However, the current market in Vietnam only favors
quality auditing waste in industrial facilities, one of the goals of environmental
auditing, and the importance of environmental auditing has not yet approached iii
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the standards implemented around the world. With the Vietnamese standard
(TCVN) 14000 regulated environmental management systems promulgated in
1997, built on the basis of the ISO 14000 standard system, in the near future,
environmental auditing will become a necessary and effective tool in Vietnam for
evaluating different environmental objectives. On the other hand, now that
Vietnam's Environmental Law has regulations on projects subject to EIA, auditing
the environment proves to be an important tool in the field of environmental management. iv
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Chapter 1. Overview of environmental audits
1.1. Origins of Environmental Auditing
Environmental safety and health auditing developed in the early 1970s, largely
among companies operating in environmentally intensive sectors such as oils and
chemicals. Since then environmental auditing has spread rapidly with a
corresponding development of the approaches and techniques adopted. Several
factors have influenced this growth.
Industrial accidents. Major incidents such as the Bhopal, Chernobyl and
ExxonValdez disasters have reminded companies that it is not sufficient to set
corporate policies and standards on environmental health and safety matters
without ensuring that they are being implemented. Audits can help reduce the risk of unpleasant surprises.
Regulatory developments. Since the early 1970s regulations on environmental
topics have increased substantially. This has made it steadily more difficult for a
company to ascertain whether a specific plant in a particular country is complying
with all of the relevant legislation.
Public awareness. The public has become increasingly aware of, and vocal about,
environmental and safety issues. Companies have had to demonstrate to the public
that they are managing environmental risks effectively.
Litigation. The growth of legislation has led to a corresponding explosion of
litigation and liability claims, particularly in the United States. In Europe and
elsewhere, there is growing emphasis on the responsibilities of individual
directors and on making information available to the public.
1.2. Objectives and scope of Environmental Auditing
1.2.1. Objectives of Environmental Auditing
The overall objective of environmental auditing is to help safeguard the
environment and minimize risks to human health. Clearly, auditing alone will not
achieve this goal (hence the use of the word help); it is a management tool.
The key objectives of an environmental audit therefore are to: 1
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determine how well the environmental management systems and equipment are performing •
verify compliance with the relevant national, local or other laws and regulations •
minimize human exposure to risks from environmental, health and safety problems.
1.2.2. Scope of the Audit
As the prime objective of audits is to test the adequacy of existing management
systems, they fulfill a fundamentally different role from the monitoring of
environmental performance. Audits can address one topic, or a whole range of
issues. The greater the scope of the audit, the greater will be the size of the audit
team, the time spent onsite and the depth of investigation. Where international
audits need to be carried out by a central team, there can be good reasons for
covering more than one area while onsite to minimize costs.
In addition, the scope of an audit can vary from simple compliance testing to a
more rigorous examination, depending on the perceived needs of the
management. The technique is applied not only to operational environmental,
health and safety management, but increasingly also to product safety and product
quality management, and to areas such as loss prevention. If the intention of
auditing is to help ensure that these broad areas are managed properly, then all of
these individual topics must be reviewed. Items which may be addressed in audits,
including environment, health, safety and product safety are shown in table 1.
Table 1. Scope of environmental audit
Environmen Safety Occupational Product Safety tal Health -Site history -Safety -Employee -Product safety
-Process/mat policy/procedures - exposure to air program erials - contaminants - Storage of Accident reporting Exposure to -Product quality -Accident recording control 2
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-Measurements of recall/withdrawal ground -Special procedures employee procedures - -Air for confined space exposure Customer emissions - entry, work on
-Exposure records information on Water electrical
-Ventilation/engin product handling discharges -
equipment, breaking eering controls - and quality - Liquid/haza into pipelines, etc. Personal Regulatory rdous wastes -Emergency protective compliance -Asbestos - response equipment -Labeling Waste -Firefighting
-Information and -Specifications for disposal
-Job safety analysis training on purchased onsite -Safety training health hazards - materials/products/pac offsite -Safety Medical kaging
-Oil/chemica communication/pro surveillance -Materials safety data motion - l spill Housekeeping - program - -Vendor qualification prevention - Regulatory Hearing program Permits/lice compliance conservation -QA testing and nses -First aid inspections - -Regulatory Record keeping requirements -Product literature -Process control
Although some companies have a regular (often annual) audit cycle, audits are
primarily determined by need and priority. Thus not all facilities or aspects of a
company will be assessed at the same frequency or to the same extent.
1.3. Ideas and functions of environmental audit
1.3.1. Benefits Derived from Environmental Auditing 3
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- The primary benefit readily apparent is environmental protection, whichensures
compliance with environmental laws, enhances investment efficiency, and aligns
with facility policies. Many companies have established internal environmental
standards and guidelines, widely applicable and adaptable to local laws and regulations.
- Environmental auditing yields numerous additional benefits, such as
improvingmanagement levels and enhancing workers' awareness and
responsibility regarding environmental issues, thereby fostering overall
environmental management improvement.
- Environmental audits facilitate an independent examination of whether
currenteconomic activities or policies comply with existing and anticipated environmental laws.
- Facilitate information exchange between production facilities (for
example,identifying disparities in environmental standards between factories
producing the same product, allowing corrective action based on audit findings).
- Evaluate training programs and support staff training initiatives. - Provide comprehensive information about the facility's current
environmentalstatus, offering data and databases for emergency situations and prompt responses.
- Identify errors and areas of ineffective management, proposing
correctivemeasures to enhance technological efficiency and reduce waste. -
Prevent and mitigate short-term and long-term environmental risks.
- Enhance the company's image and strengthen relationships with
relevantagencies. Environmental auditing may yield specific benefits tailored to
individual cases, supplementing the general advantages mentioned above.
1.3.2. Functions of Environmental Audit
- Environmental audit serves as the cornerstone of management (e.g.,
identifyingpotential environmental issues early).
- Functions as a planning tool. 4
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- Serves as a source of information (e.g., for illegal trading in real estate
andcompanies acquiring such properties).
- Considered a fundamental document for insurance purposes (e.g., for risk andhazard control).
- Functions as a training tool for all staff, including facility personnel
(e.g.,environmental tools in schools, training officials, and employees).
- Serves as a means of information exchange with external parties (e.g., thepublic, authorities).
The overarching objective of environmental auditing is to provide guidance for
effective management of environmental aspects, systems, and equipment within operational departments.
1.4. The essentials of an environmental audit
Environmental audits involve on-site inspections of both on-site and off-site
activities. The necessary steps of an audit include collecting information,
evaluating the information, drawing conclusions, and identifying areas that need
improvement. To have an effective environmental audit and gain maximum
benefits, the following factors are essential, according to the International
Chamber of Commerce (ICC, 1989):
1.4.1. Full commitment from management:
A systematic and effective environmental audit program must receive public
support from leaders at all levels. This commitment should be clearly
demonstrated in practice, such as through the board of directors or top
management showing a special interest in implementing company policies,
accepting and enforcing standards, and defining appropriate human resources for post-audit activities.
1.4.2 Objectivity of the audit team:
Key members of the audit team must be impartial, objective, and competent to
ensure objectivity in their work. The audit team should be selected appropriately
based on the size, structure of the audited facility, and the nature of the specific audit. 5
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1.4.3 Professional capacity:
Members of the audit team need to have appropriate expertise to provide basic
technical knowledge and assess the current status of the audited problem. This
includes understanding environmental issues and policies, providing specific
environmental expertise, and having operational experience and knowledge of environmental control.
1.4.4 Cooperation of audited facility staff:
The audit method requires the full cooperation of staff within the facility to ensure
effectiveness. Therefore, it is important to ensure that facility staff perceive the
audit as a measure to actively contribute to the implementation of an effective
environmental management system, rather than a "error-finding" procedure.
1.4.5 Systematic and clearly defined procedures:
Audit procedures should be systematic and clearly defined to ensure that all audit
issues are covered and that audit methods are effectively implemented according to the audit plan. 1.4.6 Audit report:
The final results of the environmental audit process should be properly
documented, and a clear report should be submitted to appropriate facility
management, the client, and other stakeholders, depending on the type of audit.
The audit report must include objective and factual observations.
1.4.7 Quality assurance:
The quality of audit reports needs to be guaranteed and should demonstrate the
certainty, quality, and stability of the audit process.
1.4.8 Post-audit activities:
To ensure the effectiveness of the audit and maximize the value of the audit
process, proactive corrective activities should be carried out, and next steps for
the audited issues should be determined.
By following these essential factors, an organization can conduct a comprehensive
and effective environmental audit to assess its environmental performance, 6
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identify areas for improvement, and enhance its environmental management practices.
1.5. Contents of environmental audit
It is important to draw the distinction between auditing and techniques such as
environmental impact assessment (EIA). The latter assesses the potential
environmental effects of a proposed facility. The essential purpose of an
environmental audit is the systematic scrutiny of environmental performance
throughout a company’s existing operations. At best, an audit is a comprehensive
examination of management systems and facilities; at worst, it is a superficial review.
The term environmental audit means different things to different people. Terms
such as assessment, survey and review are used to describe the same type of
activity. Furthermore, some organizations consider that an “environmental audit”
addresses only environmental matters, whereas others use the term to mean an
audit of health, safety and environmental matters. Although there is no universal
definition, auditing, as practiced by many leading companies, follows the same
basic philosophy and approach summarized by the broad definition adopted by
the International Chambers of Commerce (ICC) in its publication Environmental
Auditing (1989). The ICC defines environmental auditing as: a management tool
comprising a systematic, documented periodic and objective evaluation of how
well environmental organization, management and equipment are performing,
with the aim of helping safeguard the environment by:
(i) facilitating management control of environmental practices and
(ii) assessing compliance with company policies which would include
meetingregulatory requirements.
The European Commission in its proposed regulation on environmental auditing
also adopts the ICC definition of environmental audit.
1.6. Types of audit and types of environmental audit 1.6.1. Legal audit 7
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Forensic audit involves a review examination -
Main goals of the country's environmental policy.
- How is the current law's ability to reach these goals?
- How can the law be best amended?
Areas to consider include State policies on the ownership, use and management
of natural resources and what laws and regulations the State has enacted to control
pollution and maintain natural resources. maintain environmental quality. Due to
such a macro level, this type of legal audit is often within the scope of national
research and is rarely used locally.
Auditing belongs to the organization
This type of audit includes information about the management structure within a
company, ways of communicating information internally and externally, and
training and exercise programs. Check
The organizational audit uncovers details, such as: the history of the factory and
the names of the factory manager, the person responsible for environmental issues,
the purchasing agency, the consultant, and laboratory manager (Blakeslee and
Grabowski,1985). This type of audit is especially useful in exchanging
information or in real estate business. 1.6.2. Technical audit
A technical audit reports the results obtained from measurements, observations,
and studies of water and air pollution, hazardous waste, and solid waste.
radioactive materials and minerals (asbestos) (Tomlinson. 1987). For example, an
air emission source audit is an audit that researches and reports results on types of
air emission sources including the type of source, type and age of mechanical
systems, and performance of air sources. control device, location, altitude and
discharge volume (capacity) of the discharge point.
Technical audits are the most common and widespread type of audit, especially
often used to audit industrial production facilities, such as waste audits or gas emission source audits. 1.6.3 Waste audit 8
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Waste audit is a type of technical audit that is most commonly and widely used at
industrial facilities in developed countries. Waste audits are usually internal audits
conducted by companies themselves, with the goal of understanding sources of
material loss and pollution through building a material balance. Based on the audit
results, corrective measures are proposed such as replacing raw materials;
Improve production processes to prevent immediate waste generation at the
Source, thus saving raw materials while improving production efficiency and
improving the environment towards the goal of "cleaner production". In reality in
our country today, waste audit is a type that is beginning to be applied in typical factories.
- Auditing gas emission sources
Air emission source audit is a typical form of technical audit. In the air pollution
control program, analysis should be carried out in a parallel wall atmospheric
section, meteorological observation, determination of thegreed number of waste
sources and concentration of pollutants in the environment, they depend very much on the waste source.
To manage the environment and reduce pollution, it is first necessary to audit the
waste source, that is, to identify it from waste source, geometric size of waste
source, as above with Chimney is size afternoon High,road oral glass tube smoke,
parameters of the exhaust source: amount of pollutant released into the
atmosphere per unit of time, exhaust gas flow (smoke flow), as well as the
temperature of the exhaust gas.
1.7. Environmental audit - A component of an environmental management system
1.7.1 Environmental Management System (EMS)
An Environmental Management System (EMS) is a structured framework that
organizations implement to manage their environmental responsibilities
effectively. It provides a systematic approach to identify, control, and
continuously improve environmental performance. Here's more detailed information about EMS: 9
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a, Purpose of Environmental Management System:
The primary purpose of an EMS is to help organizations minimize their
environmental impacts, comply with legal requirements, and achieve their
environmental objectives. It provides a framework for integrating environmental
considerations into daily operations and decision-making processes. b, Components:
An EMS typically consists of the following key components:
- Policy: A written statement from top management that outlines theorganization's
commitment to environmental protection and compliance. - Planning:
Identification of environmental aspects (such as emissions, waste generation,
energy consumption) and associated impacts, setting environmental objectives
and targets, and establishing programs to achieve them.
- Implementation and Operation: Allocation of resources, training of personnel,
establishment of operational controls, and communication of environmental
responsibilities and procedures.
- Monitoring and Measurement: Regular monitoring, measurement,
andevaluation of environmental performance against objectives and targets, as
well as legal and other requirements.
- Review and Improvement: Periodic management review of the EMS toensure
its continued suitability, adequacy, and effectiveness, and implementation of
corrective and preventive actions to address deficiencies and drive continual improvement. c, Standards:
The most widely recognized standard for EMS is ISO 14001, developed by the
International Organization for Standardization (ISO). ISO 14001 provides a set of
requirements and guidelines for establishing, implementing, maintaining, and
improving an EMS. Organizations can seek certification to demonstrate
compliance with ISO 14001, enhancing their credibility and reputation. d, Benefits:
Implementing an EMS offers several benefits to organizations, including: 10
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- Improved environmental performance and compliance with regulations. -
Enhanced resource efficiency and cost savings through better management of energy, water, and materials.
- Reduced risks of environmental incidents and liabilities.
- Increased stakeholder trust and confidence, including customers,
regulators,investors, and the public. - Opportunities for innovation and competitive advantage in
environmentallyconscious markets.
e, Integration with Other Management Systems:
An EMS can be integrated with other management systems, such as quality
management (e.g., ISO 9001) and occupational health and safety management
(e.g., ISO 45001), to create a more comprehensive approach to organizational
management known as an Integrated Management System (IMS).
Overall, an EMS provides a systematic framework for organizations to manage
their environmental impacts, improve sustainability, and demonstrate
commitment to environmental stewardship and corporate social responsibility.
1.7.2 Environmental audit - A component of an environmental management system
From the definition of environmental audit given by the ICC Institute of
International Trade in 1989, it is obvious that environmental audit is a part of the
environmental management system and is a practical and effective tool. It is an
examination or review of some aspect of environmental management and provides
guidance for improving those aspects or components. Environmental auditing
provides practical, effective and fast tools in developing projects, managing
resources and developing sustainably. They are used very widely and very
successfully in developed countries.
The environmental management system audit aims to consider a series of established actions:
- The environmental management system operates appropriately and in
accordancewith the environmental program. 11
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- The environmental management system is well implemented. - The environmental management system operates effectively in
implementingenvironmental policies, environmental goals and targets of the facility.
- The facility complies with regional, national and international
environmental,health and safety regulations.
- Risks related to environmental defects have been identified.
- Any environmental improvement needs to be considered.
Along with valuable previous data, the information obtained from an environmental
audit will assist in improving the facility's environmental management system. In
addition, the information obtained during the assessment serves a variety of other facility benefits including:
- Increase environmental awareness among facility employees.
- Increase the image of the facility.
- Create opportunities for leaders to increase the company's reputation forenvironmental performance. - Avoid fines and lawsuits.
- Update environmental data so that decisions or modifications can be made withinthe facility.
- Evaluate training programs for employees. Sometimes, some aspects of
theenvironmental audit procedure are not beneficial to the facility. Examples
include initial costs of assessment, costs of conformance and decommissioning
of facility operations. However, if the facility has committed to its environmental
management system, the above benefits will be higher costs for carrying out
audits to facilitate the effective implementation of the environmental management system.
Since an audit is completed, the audit results will give a clear indication of the
performance of the environmental management system.
An environmental management system audit also involves considering the
effectiveness of environmental policy transformation in enhancing environmental 12
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performance within the facility. In practice, auditing an environmental management
system often involves the environmental management system itself. How often to
audit the environmental management system? Depends on the level of risk
associated with environmental activities. When this level of risk is high, the
frequency of assessments will be greater. Such an application will be made if the
results of previous audits are questionable. In other words, more audit frequency is
required to ensure that corrective actions are effective in resolving problems. The
specific environmental management system may specify a time period for the
assessment of the environmental management system. For example, ISO 14001
requires organizations to complete an audit cycle within three years.
1.7.3 Role of Environmental audit within EMS
Environmental Audits within (EMS): Environmental audits serve as a tool for
assessing the effectiveness of an organization's EMS. They help verify whether
the organization is complying with environmental policies, meeting objectives,
and continually improving its environmental performance.
- Evaluation of Compliance:
Environmental audits within an EMS often include evaluating the organization's
compliance with environmental regulations, laws, permits, and other
requirements. This ensures that the organization is meeting its legal obligations
and reducing the risk of regulatory non-compliance.
- Internal and External Audit:
Environmental audits within an EMS can be conducted internally by the
organization's own personnel or externally by independent third parties. Internal
audits are typically conducted by trained staff within the organization, while
external audits may involve certification bodies or regulatory agencies.
- Identification of Non-conformities:
Environmental audits help identify non-conformities, deficiencies, or areas for
improvement within the EMS. These may include gaps in compliance, deviations
from established procedures, or opportunities for enhancing environmental
performance. - Continuous Improvement: 13
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Through the findings and recommendations of environmental audits,
organizations can implement corrective and preventive actions to address
nonconformities and drive continual improvement in their EMS. This iterative
process aligns with the "Act" stage of the PDCA cycle.
Overall, environmental audits play a vital role within an EMS by providing
feedback on environmental performance, ensuring compliance with regulations,
and driving ongoing improvement efforts. They help organizations systematically
manage their environmental responsibilities and achieve their sustainability objectives.
1.8. The relationship between environmental audit and some other instruments
Environmental auditing is one of the most effective management tools within the
environmental management system, thus it has a close relationship with several
other tools and components within the environmental management system such
as environmental impact assessment, environmental monitoring, environmental
inspection, environmental economics, environmental standards, environmental criteria, etc.
Environmental inspection is the process of examining the level of compliance with
regulations, standards, and laws protecting the environment of economic and
social activities. Environmental inspection is tasked with overseeing compliance
with legal regulations on environmental protection (standards, regulations on
prevention, control, and mitigation of environmental degradation, environmental
pollution, environmental incidents during the use and exploitation of
environmental components) by organizations and individuals. The work of
environmental inspection is closely related to environmental auditing. However,
a fundamental difference between environmental protection inspection and
environmental auditing is the form of implementation. One of the tasks of
environmental protection inspection is to conduct compulsory inspections to
ensure that production facilities comply with committed environmental standards.
Any production facility that violates environmental protection laws or regulations 14
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