In today's rapidly evolving regulatory environment, meeting compliance obligations is more than a legal requirement—it's a business imperative. For organizations committed to excellence in Environmental, Health, and Safety (EHS) management, a well-designed and agile EHS audit program is a vital tool. Beyond simply checking boxes, it helps identify risks, protect workers, ensure environmental stewardship, and drive continuous improvement.
This blog explores the key elements of a successful EHS audit program, the critical role of the Audit Program Manager, and how to effectively integrate emerging regulatory requirements to stay ahead of change.
Essentials of an EHS Audit Program
An EHS audit program is a structured, documented, and objective process used to evaluate an organization’s EHS policies, procedures, and performance against legal requirements, corporate standards, and industry best practices. Its purpose is not only to ensure compliance but also to reduce operational risk and strengthen EHS performance over time.
An effective audit program clearly defines:
- Objectives: What the audit seeks to achieve
- Scope: What areas or operations will be audited
- Criteria: What standards, regulations, or benchmarks will be used
To ensure consistency and quality, organizations often align their audit programs with established frameworks such as:
- ISO 19011:2018 – Guidelines for Auditing Management Systems
- The Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing (IPPF)
The Critical Role of the Audit Program Manager
At the heart of every successful audit program is the Audit Program Manager—the individual responsible for establishing, implementing, and maintaining the program in alignment with organizational goals and compliance requirements.
This role involves close collaboration with a diverse group of stakeholders, including:
- EHS professionals
- Facility and operations managers
- Maintenance and engineering teams
- Legal, compliance, and HR teams
- Quality assurance and internal audit groups
- Senior management and IT/data teams
- External partners such as third-party auditors, consultants, suppliers, and certifying bodies
Early and continuous engagement with these stakeholders helps define relevant objectives, identify constraints (such as resource limitations), and assess both internal and external risks and opportunities.
Key responsibilities of the Audit Program Manager include:
- Defining audit scope and selecting appropriate criteria
- Assembling and evaluating qualified audit teams
- Scheduling and coordinating audits
- Determining audit methods
- Managing communication and dispute resolution
- Ensuring follow-up, reporting, and continuous improvement
To maintain program relevance and effectiveness, regular reviews—at least annually—are strongly recommended. These reviews help address operational changes, lessons learned, and emerging issues.
Integrating Emerging Regulatory Trends
Adapting the audit program to include new or evolving EHS regulations is essential for maintaining compliance in a dynamic regulatory landscape. But simply updating the audit checklist is not enough—a holistic and strategic review is required to fully understand the impact of regulatory change on your organization.
Case in Point: PFAS
PFAS (per- and polyfluoroalkyl substances) are a prime example. These substances were rarely addressed in legacy audit programs, but with increasing regulation across the globe, organizations must now consider PFAS in their audit scope.
To do so effectively, Audit Program Managers should:
- Engage stakeholders to evaluate PFAS-related risks and obligations
- Determine whether PFAS requirements should be included in the audit scope
- Assess the need for additional auditor training or expertise
- Decide whether to apply PFAS criteria organization-wide or based on jurisdictional risk
- Evaluate whether PFAS should be part of existing audit cycles or require standalone audits
- Revise audit agendas to accommodate new compliance checks
Other Emerging Areas to Watch
This same comprehensive approach should be applied to other regulatory developments gaining momentum in North America and globally, including but not limited to:
- Heat illness prevention
- Ergonomic standards
- Workplace violence prevention
- PPE fit and suitability requirements
Staying proactive ensures your audit program remains relevant and risk-based, rather than reactive and outdated.
Stay Informed and Stay Ahead
Maintaining a high-performing audit program requires constant awareness of the regulatory landscape. Consider these strategies to stay current:
- Subscribe to STP Compliane EHS’s RegHub and AuditHuba Regulatory Content Provider, such as STP, that provides frequent monitoring of EHS requirements and audit protocols tailored to your organization
- Subscribe to industry newsletters and government regulatory updates
- Engage with professional associations (e.g., AIHA, ASSP, NAEM)
- Attend EHS webinars, conferences, and training sessions
- Monitor reputable EHS blogs and legal alerts
Final Thoughts
A strong, agile EHS audit program is one of the most effective tools an organization can use to manage compliance, reduce risk, and promote a culture of safety and accountability. By aligning with proven frameworks, engaging stakeholders, and staying ahead of regulatory trends, your audit program can evolve into a strategic asset—positioning your organization for long-term success in a complex and fast-changing world.
About the Author
Prior to joining STP as the Director of Partnerships in 2021, Shannon spent 14 years as an EHS consultant performing EHS compliance and management system audits, as well as implementing ISO 14001 and 45001 conforming management systems for organizations within the construction, manufacturing, health care and commercial retail industries.
She is a trained ISO 14001 and 45001 Lead Auditor and a certified environmental auditor with ECO Canada. She lives in Ontario, Canada with her family, where she loves to play any sport especially soccer.
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