Audit Season: What to Expect

Has your concession operation been scheduled for an environmental audit this season? Are you prepared and know what to expect? Just want to know more about environmental audits? Read on to learn about the National Park Service (NPS) Commercial Services Program’s Environmental Audit Program (EAP)!

The primary purpose of the Commercial Services Program’s EAP is to assist concessioners review and check the compliance of their operations against:

• Applicable federal, state, and local environmental laws and regulations
• Department of the Interior (DOI) and NPS policies
• Concessioner contract requirements
• Other criteria, as applicable

The DOI’s environmental audit policy was implemented in September 1997 to ensure compliance of DOI facilities and operations with applicable environmental regulations. The DOI policy requires that all bureaus and offices develop and implement an environmental audit program. In line with the policy, the Commercial Services EAP was initiated in March 1998. Related policies and procedures have been updated on a regular basis, with the most recent update to the EAP in 2018. The EAP currently monitors approximately 550 concession operations. In addition to checking compliance with the environmental and contract requirements specified above, EAP audits also:

• Allow concessioner-implemented best management practices (BMPs) to be recognized and identify opportunities for implementation of new BMPs.

• Promote sustainability and allow for “exceptional practices” recognition to those concessioners that demonstrate superior environmental stewardship and management.

Learn more about the EAP visit.

Are there different types of audits?

The Commercial Services Program conducts three types of audits: paper, phone, and site visits. In part, the type of audit a concessioner receives is determined by the concessioner’s contract category (i.e., I, II, or III). Category III concessioners do not have assigned facilities inside park boundaries. These concessioners generally receive either a phone or paper audit. Category I and II concessioners (i.e., concessioners with assigned facilities inside park boundaries) can generally expect a site visit audit. Multiple concessioners at the same park are usually grouped together to receive audits during the same site visit. In addition to the contract category, The Commercial Services Program uses an Excel-based “risk analysis tool” to identify concessioners with assets and operations that pose a higher risk of environmental impact to park resources. During the 2018 audit season, 19 site visits and 46 phone audits were completed. Twelve site visits and 32 phone or paper audits are scheduled for the 2019 audit season this fall.

What is the scheduling process?

Audits are scheduled every three to five years, based on prioritization established by the risk analysis tool. Audit data is uploaded and continuously updated. The risk analysis tool requires responses to the following questions:

• Have prior audits been closed out on time?

• Were findings addressed in a timely manner?

• Does the concessioner have assets on-site, and is the concessioner responsible for maintenance?

• What is the size of the concessioner’s business?

• Do the concessioner’s operations include aboveground or underground storage tanks?

• Does the concessioner conduct on-site fueling operations or handle hazardous waste?

The risk tool ranks each facility and determines which locations should be scheduled for a site audit. If prior audits have been closed-out on time, and audit findings addressed in a timely manner (regardless of type of finding), a concessioner can generally expect an audit every five years, as opposed to every three years. For this reason, it is important and beneficial to promptly comply with all stages of the audit process!

Audit Process and Timeline

What is a pre-audit?

The pre-audit begins six weeks before the scheduled audit. During this time, the audit team gathers information and works on logistics for the upcoming audit. The auditor will send the concessioner a pre-audit questionnaire to complete. If you are scheduled for a site visit or a paper audit, the questionnaire should be filled out in its entirety and sent back at least one week prior to your scheduled audit. For a phone audit, it is recommended that you review the questionnaire and be prepared to answer the questions during your audit telephone call. The questionnaire guides you through a list of all operations that you perform under your contract that could impact the environment. Some examples of these include:

• Types of vehicles owned and used
• Waste handling methods
• Pesticide use

The more information you provide in each section, the better, as it will allow the auditors to more efficiently conduct the audit.

How is the audit conducted?

During a site audit, the audit team will tour your facilities (or ask questions for a phone audit) and point out and discuss potential audit findings, BMPs, and exceptional practices. Take note of your operational BMPs for your records, as they will not appear in the audit report. The audit team will also inform you about the Corrective Action Tracking (CAT) process, which will be used to close-out any findings noted in the audit report. Before concluding the audit, the auditors will schedule a conference call to discuss comments, if needed.

What is the Preliminary Audit Report?

Three to four weeks after the audit, you can expect a preliminary audit report. This audit report will contain the following:

1. An executive summary

2. Priority 1, 2, and 3 findings with descriptions:

   • Priority 1 findings are those that pose an immediate actual or potential harm to human health or the environment; or have the potential for significant financial or legal liability. While any immediate threats must be remedied immediately, 90 days is allotted from the date of the preliminary report to allow for the full scope of the problem to be addressed and regulatory paperwork to be filed.

   • Priority 2 findings are non-conformance with laws or regulations that do not pose an immediate threat to human health or the environment and must be reconciled within 180 days from the date of the preliminary report.

   • Priority 3 findings are non-conformance with policies or procedures and must be reconciled within 180 days from the date of the preliminary report.

3. Any exceptional practices found

4. Necessary photos that relate to the report

5. Assistance resources

6. An Excel Corrective Action Tracker (CAT)

Once the preliminary audit report is received, the concessioner is asked to provide comments using the CAT.

What happens after the audit?

Within two weeks of receiving the preliminary audit report, the audit team will conduct a comment call with the concessioner to review the CAT comments. One week after the comment call, the final environmental audit report will be provided. An audit is considered closed when all findings have been addressed, and closure verified by the park.

What are the most common audit findings?

There are approximately 20 different categories of audit findings, regardless of the type of audit conducted. Over the past five years, the most common types of findings noted are the management of hazardous materials, fuel storage, and solid waste (see findings count in each category below); these are all priority 2 or 3 findings.

Hazardous Materials Management

Hazardous Materials Management findings relate to the storage and transportation of hazardous materials or chemicals. These types of findings can include, but are not limited to:

• Incompatible materials stored together
• Unsecured containers
• Incomplete or missing hazardous chemicals lists
• Lack of appropriate signage

Fuel Storage Management

Fuel Storage Management findings relate to the storage and dispensing of fuel. These types of findings can include, but are not limited to:

• Tank equipment and connections
• Inspections that are not occurring or not properly documented
• Incomplete recordkeeping
• Incomplete or missing warning labels
• Having fuel storage in areas that are not secured or are susceptible to damage

Solid Waste Management

Solid Waste Management findings relate to the storage and transportation of solid waste, including recyclables. These types of findings can include, but are not limited to:

• Inappropriate pick-up trucks
• Storing waste in a manner that does not prevent animals and pests from tampering with the waste
• Wastes not being removed in a timely manner

In Summary

It is important for concessioners to be knowledgeable about the environmental audit process and be prepared for the audit when it occurs. This makes for a more efficient and pleasant encounter for the concessioners, the auditors, and the NPS participants. Concessioners who fill out the pre-audit questionnaire completely, provide comments using the CAT, and resolve findings in a timely matter help make the Commercial Services EAP successful. While the audit process may seem daunting at first, it can be painless if you are aware of the expectations and prepare!