The Differences Between a Compliance Audit vs. System Audit

In the world of Environmental Health & Safety (EHS) various types of audits may be conducted, and each has different purposes and benefits. The approaches used by both the auditors and auditees are different depending on the type of audit. Here we break down some of the key differences between Compliance and System Audits.

Compliance Audit

A compliance audit checks for compliance to Federal, State and/or Local regulatory requirements. Compliance audits can be media-specific (e.g., air, water, hazardous materials/waste) or topic-specific (focused on a specific regulation such as: SARA-313, RCRA Subpart AA/BB/CC, Stormwater, Safety), or they can be multi-media audits combining a variety of topics. When conducted by an external regulatory agency, findings can potentially result in notices of non-compliance, administrative orders, fines and penalties. When conducted internally, legal counsel may be involved to protect the company and ensure that corrective and preventive actions are addressed in a timely manner.

Compliance audits tend to be focused on looking for areas of non-compliance. Compliance audits often focus only on addressing the specific finding (some organizations use systems to also address preventive actions). Checklists may be used in compliance audits to ensure that specific areas are checked.

System Audit

A system audit checks for conformance to an industry standard which may not be a regulatory requirement, but conformance is important to meet customer or other important stakeholder demands. Examples of industry standards for environmental management systems (EMS) and occupational health and safety management systems (HSMS) include ISO 14001, ISO 45001, Responsible Care.

System audits have a slightly different approach from Compliance audits whereby auditors are looking for evidence of conformance. In other words, system audits not only identify areas of non-conformance but also address documenting areas observed that demonstrate conformance to system requirements. System audit findings are geared toward strengthening the system, not only correcting the specific findings.

Checklists may also be used in newly established ISO systems to ensure that all components are in-place and/or identify gaps (gap analysis) to facilitate development of an action plan. Incorporating these into an electronic system, such as the EHS-Dashboard™, facilitates conducting and documenting audits.

For system audits (whether ISO management systems or compliance management systems only), it is important that the approach to the audit tests the function of the system in addition to the presence of appropriate system components. Tracing an element through the various components of the system is one way of testing linkages of the system components.

For example: If water use is a significant aspect, is there an objective/target/program to address reducing the risks and impacts? Are there operational controls and procedures? Is there a checking & monitoring, management review related to this aspect, integration with business needs and change management?

Most importantly the EMS/HSMS and its components should be adding value in achieving overall objectives of the system, whether these objectives are compliance management, improving both regulatory and non-regulatory performance, integrating with and contributing to overall business objectives.

System auditors review and evaluate objective evidence that applicable elements of the system are appropriate, effective, implemented and maintained in accordance with specified requirements. A sampling of system components and linkages are reviewed in the context of the overall program objectives. Process audit techniques are used to evaluate system function and ability of the audited processes to meet program objectives.

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