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Preparation of environmental
audit reports on risk to the
environment
Publication number 952.5* December 2015 Environmental Auditor Guideline
*This replaces publication 952.4, issued April 2013
1. Introduction 2. Purpose of these Guidelines
These guidelines apply to the conduct of environmental These guidelines have been prepared to assist
audits undertaken in accordance with Part IXD of the environmental auditors in the conduct of environmental
Environment Protection Act 1970 (the Act). audits and the preparation of environmental audit reports
In particular, these guidelines apply to those in accordance with section 53V of the Act.
environmental audits to which section 53V of the Act Others involved in the audit process who may find these
applies. Section 53V sets out requirements that must be guidelines useful include:
met when an environmental auditor prepares an • planning and other statutory authorities
environmental audit report ‘in relation to the risk of any
possible harm or detriment to a segment of the • owners of premises and others who are required
environment caused by any industrial process or activity, to, or wish to, conduct an environmental audit
waste, substance or noise’. For the purpose of these (for example, for due diligence purposes)
guidelines, the term ‘activity’ means ‘any industrial
process or activity, waste, substance or noise’. In this • recipients of a notice, direction or other
context, ‘activity’ is interpreted broadly and may include instrument pursuant to the Act, requiring them to
consideration of manufacturing industry, service industry, engage an environmental auditor to undertake an
primary industry (for example agriculture) and resource environmental audit.
management (for example water resources). For additional information on the conduct of
The scope of an environmental audit can range from an environmental audits, environmental auditors should refer
assessment of all environmental aspects of a complex to EPA publication 953, Environmental Auditor Guidelines
activity (such as large industrial premises) to a focused for Conducting Environmental Audits.
assessment of a small component of an activity. It is a requirement of the Act that environmental auditors
Examples of environmental audits of activities include have regard to these and any other relevant guidelines
audits to: when undertaking their duties as environmental auditors.1
• assess the risk to air quality from a The Authority may also provide specific guidance to
petrochemical complex environmental auditors, as requested, to clarify any
• assess the risk to surface waters and provisions in these guidelines.
groundwater from a wastewater treatment plant The failure of an environmental auditor to have proper
• assess whether a landfill cell liner has been regard to these guidelines will be considered by the
constructed in accordance with nominated Authority:
requirements, thereby minimising risks to land • in determining whether to subsequently appoint a
and groundwater person as an environmental auditor
• assess compliance of a cattle feedlot with the and
Victorian Code for Cattle Feedlots or compliance • in any review of the appointment of an
of
timber harvesting operations with the Code of environmental auditor.
Forest Practices for Timber Production
• identify risks to catchment condition from one or Refer to EPA publication 865, Environmental Auditor
a number of activities. Guidelines for Appointment and Conduct, for full details of
these matters.
These guidelines may be replaced, amended or updated
periodically. The Environment Protection Authority (EPA
or the Authority) will ensure that updates of these
guidelines are provided to all environmental auditors.
Others should refer to the EPA website for details of the
most recent EPA publications related to environmental
auditing.
1
Refer to section 53S(6) of the Act
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Preparation of environmental audit reports on risk to the environment
3. Definitions and related • of a declared industry conducted pursuant to
documents section 31C of the Act
• of an accredited licensee’s environmental
3.1 Definitions management system for the purposes of
certification of that system
Unless the context requires otherwise, an expression or • required by a court pursuant to section
phrase that is used in these guidelines has, in these
guidelines, the same meaning as in the Act or publication 67AC(2)(d) of the Act
953 (whether or not a particular meaning is assigned to it • if requested by the client (for example, as part of
in those documents). an attainment program within a site environment
Unless otherwise stated, the term environmental audit improvement plan (EIP))
used in these guidelines refers to an environmental audit • required in accordance with codes of practice or
undertaken in accordance with Part IXD of the Act. guidance incorporated under any Victorian
3.2 Related documents statute, for example, the Victorian Code for
Cattle Feedlots
These guidelines should be read in conjunction with, and • required in accordance with management or
each environmental auditor must have regard to: operational guidance such as a management plan
• the Act, particularly Part IXD – Environmental or strategy.
Audits, and regulations and policies created In circumstances where an environmental auditor is
under it unclear as to whether an audit is to be conducted in
• any other relevant legislation accordance with Part IXD of the Act, advice should be
• Environmental Auditor Guidelines for Conducting sought from the Manager Environmental Audit. Note:
Environmental Audits (EPA publication 953) Certificates or statements of environmental audit are not
generally requested when engaging an environmental
• any other guidelines prepared by the Authority auditor for the conduct of an environmental audit of an
for the purposes of Part IXD of the Act. activity. In the event that such a request is made, the
Environmental auditors should also consider the auditor should seek specific guidance from the Manager
relevance of other published standards to the particular Environmental Audit.When the Authority requires a
audit and apply them as appropriate. section 53V audit of an activity, the Authority shall
ensure the audit is not imposing costs on businesses that
are disproportionate or unnecessary by considering the
4. Responsibilities of an following criteria before requiring the section 53V audit:
Environmental Auditor 1. Is the audit targeted at preventing serious harm
to human health and the environment?
Part IXD of the Act imposes various responsibilities on 2. Is the requirement of the audit proportionate to
environmental auditors. These are explained, along with
other expectations, in EPA publication 953. the problem that needs to be addressed?
3. Is the outcome of the proposed audit understood,
5. Notification of a request to and is there another way of obtaining the same
prepare an Environmental outcome? (i.e. suitably qualified professional)
Audit Report 4. Is there a need to clearly demonstrate a high
level of independence, objectiveness, credibility
If an environmental auditor is engaged to prepare an and transparency?
environmental audit report pursuant to section 53V of the The Authority will monitor and review audits completed
Act, the environmental auditor is required to notify EPA’s that are required by the Authority to ensure they follow
Manager Environmental Audit within seven days of the criteria.
receiving the request.
Sections 6.1 to 6.6 of this Guideline provide descriptions
Notification of a request to prepare an environmental of various types of environmental audits.
audit report can be made using the notification form in
Appendix 1. It is also available from the forms section of 6.1 Environmental audits required by licences
EPA’s website (www.epa.vic.gov.au
). and notices
6. When is an Environmental Via a statutory notice or licence, the Authority may
require the person in control of an activity to engage an
Audit of an activity required? environmental auditor to conduct an environmental audit
of part or the whole of the activity.
It is impossible to provide an exhaustive list of all the In this situation, the Authority is the audit client and,
instances when an environmental audit of an activity may therefore, will define the audit objectives and must be
be required. However, examples of such instances include satisfied with the audit scope.
an environmental audit:
• required by a statutory notice or licence
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.
Preparation of environmental audit reports on risk to the environment
In such circumstances, the Authority will generally require 6.4 Environmental audits ordered by a court
that the audit scope is prepared by the environmental Under section 67AC(2)(d) of the Act, if a court finds a
auditor and approved by the Authority, in writing, before person guilty of an offence against the Act, the court may
the audit progresses. order the person to carry out a specified environmental
The environmental auditor should meet with relevant EPA audit of the activities carried out by the person.
staff to discuss the objectives of the audit and its scope. The environmental auditor must comply with directions of
6.2 Environmental audits of specified the court and must comply with these guidelines.
industries 6.5 Environmental audits and works approval
Under section 31C of the Act, the Governor in Council may application
declare an industry for which the Authority may amend The Authority requires that the proposed works would not
the licence of a premises operating in the industry to be contrary to, or inconsistent with, any applicable policy,
require the occupier of the premises to conduct a likely to cause or contribute to pollution (including
specified environmental audit using an environmental unreasonable noise), or likely to cause an environmental
auditor. hazard.
The Authority will give exemption from the environmental To address these regulatory requirements, an
audit requirement if the occupier of the premises has environmental auditor should prepare the application in
agreed to participate in an EIP that has been endorsed by the form of an environmental audit report regarding the
the Authority. risks caused by the proposed activity that accord with the
6.3 Environmental audits for accredited requirements of section 53V of the Act. In addition, an
licensees environmental auditor is required to complete and submit
Part III, Division 4 of the Act sets out a system of an assessment form, which is available from the forms
accredited licences. This part of the Act has been section of EPA’s website (www.epa.vic.gov.au).
established to allow licensees with a high standard of 6.6 Environmental audits of strategies,
environmental performance increased freedom to manage management procedures or guidance
their environmental affairs. There are two opportunities
for involvement of environmental auditors in this system: Government authorities and agencies may require an
environmental audit to be undertaken which involves the
1. certification of the licensee’s environmental assessment of the compliance with, or implementation of,
management system (EMS) in accordance with specified codes, policies, strategies or other management
Guidelines for Environmental Management or operational guidance.
System Certification (EPA publication 619) The environmental auditor should work with the client
2. participation in the licensee’s environmental (and consult with the auditee if this is a different
audit program. individual or body from the client) to establish the scope
Under these circumstances the licensee is the audit client of audit and to ensure that an effective assessment is
and must be satisfied with the audit scope. completed within the context of the nature and scale of
the auditee’s operation.
With respect to number 1 above, the audit must include an
assessment of the efficacy of the EMS in protecting 7. Audit objectives
relevant beneficial uses. The environmental auditor must
prepare an environmental audit report on the risk of any Objectives should be established for an environmental
possible harm or detriment to a segment of the audit, to guide the planning and conduct of the audit. The
environment in accordance with section 53V of the Act. objectives of a 53V environmental audit must include
Further information on the certification process can be consideration of risk to (specified segments of) the
found in EPA publication 619. environment by an activity.
With respect to number 2 above, participation in an An environmental audit may have multiple objectives.
environmental audit program would usually entail audit Some examples of additional objectives of an
planning and a review of results. The environmental environmental audit include:
auditor may undertake a lead auditor role, or may
participate as a team member in internal and/or external • assessment as to whether risks to the
audits. The audit program will vary depending on the environment are being managed adequately
nature and scale of the licensee’s operation. The • identification of risks to the environment and an
environmental auditor must be independent from the order of priority by which they should be
licensee. Further information on independence can be addressed
found in EPA publication 953.
Accredited Licensee System Guidelines for Applicants • assessment of the adequacy of implementation
(EPA publication 424) provide an overview of the audit of a code, policy, strategy or plan that manages
program requirements and guidance for environmental risks to the environment
auditors participating in such an environmental audit • an independent assessment of environmental
program. performance, for the purposes of reporting on,
for example:
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Preparation of environmental audit reports on risk to the environment
o a contractor’s environmental 9. Identifying the segment to
performance to a contract principal be Audited
or
o the environmental performances of an ‘Segment’ is defined in section 4 of the Act.
organisation (such as an industrial Segment in relation to the environment means any
facility or government agency) to a portion or portions of the environment expressed in terms
client, stakeholder and/or community of volume, space, area, quantity, quality, or time or any
group. combination thereof.
8. Defining the scope of the In a section 53V environmental audit the segment of the
environment must be described in terms of, but is not
Audit limited to:
Sections 9–13 of these guidelines address the components • the geographical extent including:
of the scope in detail. o the boundaries of the premises or land
Definition of the scope of an environmental audit should area (such as a catchment) on which the
include, but not be limited to, a description of the: activity is conducted
• activity undertaken (in respect of which the o that portion of the surrounding
environmental audit is to be conducted) environment to which the activity may
pose a risk that will be considered
• components of the activity to be considered • the time frame to which the environmental audit
• segment/s of the environment to be considered applies.
• element/s to be considered 10. Identifying the elements to be
• beneficial uses to be considered considered
• risk assessment to be conducted
• period of time over which the audit is to be In identifying the elements to be considered in an
conducted environmental audit, consideration should be given to
each of the principal constituent parts of the environment
• exclusions from the scope of the audit. as set out within the Act, including:
The scope should also state whether risks associated with • waters (surface waters and/or groundwater)
abnormal operating conditions of the activity will be • atmosphere
considered, and the level of stakeholder involvement.
In many cases, some form of risk assessment may be • land
required to determine which components of the activity • vegetation
should be included in the audit scope (refer to section • climate
14.4 of these guidelines).
The environmental auditor should ensure that the client • sound
agrees to the proposed scope, and the auditor should be • odour
satisfied that it will enable the objectives to be met, • aesthetics
before proceeding with the environmental audit. If the
auditee is different from the client, the auditee should • fish
also be consulted about the proposed scope. Any changes • wildlife.
to the audit scope should be documented and agreed to
by the environmental auditor and the client and Where relevant, any other elements of the environment
communicated to the auditee (if different from the audit should also be considered.
client).
The environmental audit scope and objectives must be
clearly stated in the environmental audit report.
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