Conducting the verification

Before engagement

Before agreeing to undertake a verification, ensure:

• the verification is a prescribed function of an environmental auditor pursuant to Regulation 164
• the scope and objectives are clearly defined and understood by all relevant parties. Discuss with the duty holder and EPA as required
• you can remain independent in your assessment, opinions and conclusions
• the scope is within your area of competence. Use independent expert support as required
• you clearly communicate what documentation you will need to review and the timeframe within which the duty holder will need to provide this.
  

Independence and conduct of environmental auditor

Refer to Environmental auditor guidelines for appointment and conduct. These include general expectations and requirements for conduct during environmental audits and preliminary risk screen assessments. These expectations and requirements also apply to verifications.

Demonstrate your independence from the duty holder. It is your responsibility to maintain your independence when completing any function as an environmental auditor.

Acknowledge any potential or perceived conflicts of interest. Note these in the verification report and, if required, outline the mitigation measures you took to manage and respond to those conflicts.

It is generally considered inappropriate for you to verify:

• work completed by you or your company. For example, if you direct remediation works required by a remediation action plan, it’s not appropriate for you to verify the plan’s implementation
• verify something you or your company had recently advised on (while not engaged as an environmental auditor). For example, if your company recently provided advice on environmental management controls required to address stormwater pollution, it would not be appropriate for you to subsequently verify that risks associated with stormwater pollution had been addressed.

Undertaking the verification

Consider:

• the accuracy, quality and representativeness of information being relied upon or verified
• the qualifications and experience of the organisation(s) or person(s) collecting or providing information you rely on
• reviewing the conceptual site model (CSM) to ensure you understand site characterisation and risk
• whether works were in accordance with relevant standards and guidance
• if the requirement or recommendation being verified has been met
• requesting further data or information if required to complete the verification (e.g. requesting additional sampling to be undertaken).
  

Investigation and sampling

Consider if it is desirable or appropriate for you to collect your own information to support the verification. For example, a site inspection to observe risk controls are in place, collection of samples or measurements to confirm a condition or requirement. It is not expected that you would undertake a full sampling program, rather samples would only be collected if deemed necessary to validate a specific condition or requirement.

Such investigation work should aim to verify a condition or requirement. It would generally not be for quality assurance purposes. For example, where a consultant has already completed investigation works and you have the results.

Risk assessment

You may be expected to verify that a risk assessment has adequately addressed risk of harm. In this work you would have to agree or disagree with various elements of the risk assessment. However, it would generally be considered beyond the scope of a verification for you to complete your own formal risk assessment based on your own categorisations of risk.

Resolving information gaps

If you do not receive adequate information to complete a verification, first discuss this with the person or party who has engaged you.

If you can’t resolve issues, and the verification relates to an EPA requirement, inform the duty holder to discuss this with EPA.

Incomplete verifications

If you are not able to verify that a condition or requirement (or its intent) has been met, or that an action has been undertaken or completed:

• inform the duty holder of this
• inform the duty holder what information is needed to complete the verification
• consider if a verification report may still be of value to the duty holder (discuss this with the duty holder)
• if related to an EPA notice or permission, inform the duty holder to contact EPA to discuss the potential limitations which would be expected in a verification report. Discuss the potential to include recommendations.

Verification reports that indicate conditions or requirements have not been fully satisfied are of limited value to EPA. Obtain express permission from the duty holder and agreement from EPA before completing such a report. The verification report should explicitly state the condition or requirement that could not be verified.

Discontinuing a verification

You may not be able to complete a verification for many reasons. In this circumstance, inform the duty holder to discuss with EPA.

Writing the verification report

Verification reports should provide sufficient information so that a reader can understand how you reached your conclusion(s). You should comment on – rather than reproduce – the information you have reviewed during the verification.

Clearly document:

• the person or organisation who requested the verification
• the objective(s) and scope of the verification
• the site, area or activity that the verification relates to
• background information that explains why the verification is required, any relevant considerations from site history, etc.
• the standards, references and guidance you adopted to complete the verification. For example, verification of a detailed site investigation may involve considering if it was in accordance with the National Environment Protection (Assessment of Site Contamination) Measure 2013
• the information you relied on or verified. Attach any key documents like reports, survey data, design drawings, etc.
• the details and results of any site inspections, tests or analyses you undertake
• information demonstrating the CSM is well understood (if relevant)
• any data gaps or uncertainties
• any assumptions or limitations you make in completing the verification
• a clear statement that each requirement or condition being verified has or has not been met.

Download an example table for presenting verification results:

Verifying the intent of a condition or requirement has been met

If you are not able to verify specific conditions or requirements, sometimes it may be evident that the intent of a condition or requirement has been met.

Clearly address this in the verification report, like the example below.

Recommendations within a verification report

Generally, verification should not be conditional on further recommendations being met. For example, it would not be appropriate for you to verify that a sampling, analysis and quality plan meets the requirements of an EPA notice subject to additional sampling or analyses being performed.

Such recommendations may be considered when it would not otherwise be possible to complete the verification. However, the environmental auditor will need to consider how this may impact the utility of the verification (e.g., further verification may be required to ensure recommendations are implemented). You should discuss this with the duty holder and EPA before completing the verification.

You may include recommendations as additional advice based on your professional expertise. For example, in verifying the preparation of a clean up plan, you may recommend:

• it be updated periodically or to reflect the findings additional investigations being carried out
• the updated clean up plan be provided to EPA for review.
  
  

Submitting the verification report

Sign the report.

Write a cover sheet that concisely summarises key information. Download our example template.

Email the duty holder who requested the verification.

The duty holder is required to submit the verification report to EPA as stipulated in the notice or licence.

We may review your report as part of our Environmental Auditor Quality Assurance Program. This is detailed in the Environmental auditor guidelines for appointment and conduct.