Environmental Compliance Audit

An audit is a systematic, documented process for obtaining evidence and evaluating it to determine compliance with regulatory requirements. Audits help identify areas that are, or may become, non-compliant so that appropriate action can be taken. The audit program works in combination with other compliance planning and enforcement activities, as shown in the figure below.

The ministry conducts audits in accordance with the International Standards Organization (ISO) 19011:2018 and the Canadian Standards Association (CSA) Z773-17, upholding the following principles:

• Integrity
• Fair representation
• Due professional care
• Confidentiality
• Independence
• Evidence-based approach

Initiating the audit

Audit program staff provide an initiation letter to the auditee several weeks in advance of an audit. This is done to:

• inform the organization of the audit;
• establish a communication process;
• confirm the date and time of the audit;
• identify the audit objectives, scope and criteria;
• indicate topics the audit will cover; and
• note the option for audit relief.

Note: The Compliance Audit Program may also conduct an audit on information which has been previously submitted to the ministry without notification to the auditees.

Audit planning

After the audit is initiated, the lead auditor will prepare the audit plan and provide it to the auditee. The audit plan will outline the schedule for the audit, safety considerations and any other audit team requirements. Auditees may be asked to provide information about:

• hours of operation;
• contact information for key personnel;
• required personal protective equipment;
• health and safety training requirements; and
• logistical considerations (e.g. directions to site, meeting room, meals).

Conducting the audit

The audit consists of the following activities:

Opening meeting
The lead auditor facilitates the opening meeting, which takes place at the beginning of the audit. The objective is to:

• introduce the audit team;
• confirm the audit plan and summarize audit activities;
• review roles and responsibilities and confirm communication channels; and
• provide an opportunity for the auditee to ask questions.

Collect audit information and assess compliance
The audit team collects information by touring the facility, reviewing records and documents, and interviewing personnel. The audit team may take photos/videos, or scan relevant documents and records. The audit team determines whether or not the auditee is compliant based on the information collected.
*Note: the onus is upon the auditee to demonstrate compliance with regulatory requirements.

Daily Debriefs
At the end of each audit day, the audit team will hold a meeting with auditee representative(s) to discuss areas of potential non-compliance. The audit team will present what they found that day and where they require additional information. These informal discussions allow the auditee to find information to present to the audit team to demonstrate compliance.

Closing meeting
The closing meeting takes place at the end of the audit to provide preliminary findings and conclusions to the auditees, and to explain the rationale for these findings. Personnel in the auditee organization responsible for corrective actions and/or approving corrective actions are encouraged to attend this meeting.

Post-audit

The diagram below outlines the process for reporting the audit findings and preparing the corrective action plan. The lead auditor works with the auditee and ministry staff to ensure voluntary compliance is achieved.

Prior to the audit, the lead auditor will send the auditee a request for background information, such as:

• operational records (e.g. sampling, training, maintenance, monitoring);
• plans, drawings, as-built reports;
• reports (e.g. annual reports, inspections, spills); and
• emergency response plans.

The lead auditor may request this information to be sent in advance of the audit, or to have the information available during the audit. The auditee should provide requested information as quickly and completely as possible. Any information that is not sent in advance of the audit should be organized and readily accessible when the audit team arrives on site. Auditees should also ensure that key personnel will be available during the audit to answer questions.

Organizations with an internal audit program may apply to the ministry to substitute all, or part, of the ministry-led audit with results and conclusions from an internal audit. The auditee's internal audit information must meet the International Standards Organization (ISO) 19011:2018 or Canadian Standards Association (CSA) Z773-17, and be conducted by a person certified to undertake audits according to the above standards.

The lead auditor will review the internal audit to determine if it meets ISO or CSA standards. The lead auditor will inform the auditee of the relief determination and any remaining planning that needs to be completed.

The work of the Compliance Audit Section increases client knowledge of compliance obligations and reduces the risk of contamination from mining, industrial operations and landfills through compliance assurance activities.

The charts below summarize the results of audits completed by the ministry in the previous fiscal year.