Auditing waste manifests
Anyone who has conducted any audit regarding the environment will have come across a waste manifest at one time or another. If not, then you are missing out on some fun, and some easy records to audit.
Waste manifests are required documents to be completed when shipping out hazardous waste in Canada. There are similar requirements in other jurisdictions, but a lot of the points that I am covering here will be applicable and just need to be translated.
For environmental compliance auditing, it’s obvious why you would review waste manifest records, because it is a legal requirement.
For environmental management auditing, its not always as obvious. Typically, it starts from there being a significant aspect of hazardous waste generation. So you follow the process through the collection of hazardous waste, to the storage and finally the disposal. The majority of the time the waste is sent off site for disposal, even when there is on-site treatment, there is some remaining waste that is required to be shipped off-site. This is where the waste manifest comes in.
I have come across problems with this area many times. The usual reason is a lack of knowledge regarding the process. And the Ministries for Environment are starting to threaten large fines for the mishandling of this administrative activity. So as auditors, it is our responsibility to understand what is required and ensure that it is being done correctly.
First, we want to check the manifests themselves. Are they being completed by trained personnel? At the bottom of the manifest is a sign off that indicates that the person who signed the manifest is not only authorized to do so, but also verified that all the information was correct. I have seen in some places, where the driver of the pickup company signed off for the waste generating company. A big no-no! I am seeing this less and less, but it still happens occasionally. What I do still see a lot of is one of two situations: where the signer has no training, is unaware of what they are signing, and are just signing the manifest like they do all of the other shipping document; the second situation is where the driver was in a rush, they couldn’t find the trained person, and got anyone to sign it, someone who didn’t know what they were signing and were not made aware not to sign anything.
Second is the handling of the waste manifests. On the back of the manifests are the instructions regarding what is to be done with all of the different copies of the forms. The legislation also provides additional information. In Ontario, and other parts of Canada, the generator of the waste is left with the first two copies of the form. One is to be kept and the other sent away. The copy that is kept and actually has to be maintained for two years. So now this crosses into the record keeping element of the management system. Finally, the last copy is actually sent back to the generator. Most of the time it gets lost with the accounting files. But the intention is for the two copies to be matched up in order to verify that the waste ended up where it was intended to go. If the final copy is not received, an action has to be taken by the generator to investigate. This crosses over with the monitoring of the process, as well as the handling and investigating of nonconformities.
With those two reviews of manifests, we can potentially have issues with an organization’s environmental management system in a number of areas: operational control, training and awareness, monitoring, record keeping and nonconformities. And we haven’t even reviewed the legal aspects of the record. So keep these things in mind the next time you are looking into hazardous waste management and the associated records, there are a lot of little nuances and impacts on an environmental management system that you may never have considered.