Environmental auditor guidelines for conducting verifications

What is an environmental auditor verification

An environmental auditor verification is an environmental auditor confirming that something has occurred as required by, or that something complies with, a specified reference or condition (e.g. a standard, plan, document, guideline, etc.).

The main role of a verification is to provide an independent, expert view of the sufficiency and appropriateness of actions and measures undertaken to comply with the requirements of an EPA notice, order, or permission.

A verification may include the environmental auditor considering factors such as validity, accuracy, appropriateness or practicability based on application of their professional judgement.

The complexity of a verification varies. Examples include:

• Verify something has been completed in accordance with a specified standard, reference or document
• Verify an action or measure has occurred or has been undertaken
• Verify that a document or plan is appropriate.
  

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.

Example: Verification of a clean up plan under a remedial notice

We received a pollution report about a large chemical spill on unsealed soil at a chemical manufacturing plant. EPA authorised officers had reasonable belief the site had been polluted.

We issued a remedial notice with several requirements, including:

• the duty holder must develop a clean up plan
• an environmental auditor must verify the plan was prepared in accordance with EPA guidelines.

The duty holder engages a suitably qualified environmental consultant, and an EPA-appointed environmental auditor.

Before engagement

The environmental auditor confirms:

• they and their company have had no prior involvement with the site or duty holder which would compromise their independence
• they have the appropriate expertise to undertake the works.

Undertaking the verification

On receiving the clean up plan from the consultant, the environmental auditor:

• reviews the plan against relevant EPA guidelines for clean up plans, and any additional relevant requirements of the clean up plan and its verification outlined within the notice.
• notes several deficiencies and provides comments back to the consultant
• receives an updated clean up plan which addresses their comments
• prepares a verification report concluding the clean up plan in accordance with EPA guidelines that has achieved the requirements of the notice.

Given EPA is interested in ensuring the clean up plan is appropriate, the environmental auditor arranges a meeting to discuss their verification with EPA’s Environmental Audit Unit and the EPA officer who issued the remedial notice. During the meeting, the environmental auditor briefly explains the clean up plan and how they verified it.

Submitting the verification report

The environmental auditor completes and attaches the cover sheet to the verification report and submits it to the duty holder. The duty holder emails this to the EPA authorised officer who issued the notice.

After receiving the clean up plan and verification, EPA revokes the remedial notice. EPA issues a new notice to implement the clean up plan.

Example: Verification of a risk management and monitoring program (RMMP) as required by an EPA remedial notice

Medium-density fibreboard (MDF) manufacturer and wholesaler, Less Wood’s Good Pty Ltd, received an EPA improvement notice (IMPN-0000XXXX). EPA stated its risk management and monitoring program (RMMP) does not clearly identify all sources of dust and air emissions, and it is not clear whether the controls are effective.

The relevant EPA improvement notice requirement is:

By 03/04/2025 you must engage an independent EPA-appointed industrial facilities auditor appointed under Part 8.3 of the Environment Protection Act 2017 to verify that the controls stated in your risk management and monitoring program in relation to dust and air emissions are appropriate and effective.

Less Wood’s Good contacts an environmental auditor who explains that EPA requires a verification report.

Before engagement

The environmental auditor confirms:

• relevant details and requests a copy of the EPA improvement notice
• they and their company have had no prior involvement with the site or duty holder which would compromise their independence
• they have the appropriate expertise to undertake the works
• the scope of work to complete the verification, including:
  • review of existing reports and documentation to understand site conditions and potential risks
  • optional allowance for a virtual meeting with EPA and the duty holder (if required)
  • optional allowance for a site inspection for the environmental auditor to observe site activities, potential risks and current and proposed controls
  • review the RMMP and conduct a gap analysis of existing risks and controls in relation to dust and air emissions
  • preparation of an environmental auditor verification report.

The environmental auditor explains to the duty holder that EPA expects a verification report. The environmental auditor offers to meet with EPA to confirm details, if required. The duty holder agrees to proceed with the scope of work.

Undertaking the verification

The environmental auditor receives a copy of the RMMP and supporting documents from Less Wood’s Good. They undertake an inspection at the site, reviews the RMMP and considers whether it broadly meets the requirements of EPA’s guidance.

The environmental auditor provides comments for consideration including:

• some risks related to dust and air emissions did not appear to have been identified and assessed
• environmental performance objectives had not been clearly defined
• further discussion of risk control measures is required to provide an understanding of whether these manage risks so far as reasonably practicable.

Through providing comments and queries, the environmental auditor is careful not to direct the consultant or duty holder towards particular solutions, timelines, risk categorisations, etc. However, where the environmental auditor believes further information or consideration is required before they could verify that the EPA notice requirement has been met, they communicate this to the duty holder so that updates can be made as required.

The consultant responds to the environmental auditor’s comments and updates the RMMP. The finalised RMMP is then provided to the environmental auditor for review.

Writing the verification report

The background of the report summarises the reason and requirements of the verification.

The environmental auditor summarises the evidence they reviewed, as the example below shows.

Within the conclusion of the verification report the environmental auditor states:

EPA Improvement Notice IMPN-0000XXXX requires that the Industrial Facilities Auditor verify that controls stated in the Risk Management and Monitoring Program (RMMP) prepared for Less Wood’s Good Pty Ltd, in relation to dust and air emissions are appropriate and effective. As summarised above, the environmental auditor has reviewed the RMMP and supporting evidence and considers it has been prepared in general accordance with relevant EPA guidance on RMMPs

The environmental auditor recommends that if ongoing site inspections identify additional sources of dust emissions then the RMMP should be updated to address risks associated with these.

The environmental auditor completes a cover sheet. They attach the RMMP to the completed verification report.

Submitting the verification report

The environmental auditor provides the completed verification report to Less Wood’s Good. Less Wood’s Good emails a copy of the completed verification report to the EPA authorised officer who issued the notice.

Example: Verification of a hydrogeological assessment

The manager of a closed landfill site Room2Ntoom Pty Ltd contacted an environmental auditor to request verification of an updated hydrogeological assessment (HA). This was prompted by requirements of an EPA Environmental Action Notice (EAN-0000XXX).

The environmental auditor requests a copy, noting the following requirements:

• General requirement: By 11/03/25 you must engage a suitable qualified person to complete a Hydrogeological Assessment that is consistent with EPA Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines, and has been verified by an EPA-appointed Environmental Auditor.
• Reporting requirement: By 01/04/25 you must provide in writing to the Authorised Officer listed on Page 1 of this Notice a Hydrogeological Assessment, that is consistent with EPA Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines, has been verified by an EPA-appointed Environmental Auditor, and includes, but is not limited to:
  • a review of groundwater, leachate and LNAPL gauging data and laboratory analytical data available in historical reports;
  • an assessment of the adequacy of the groundwater, leachate and LNAPL monitoring network and potential data gaps;
  • the maximum levels of leachate to be maintained which minimises the impacts on groundwater and allows effective management of landfill gas.

The environmental auditor and duty holder agree on a scope for the verification engagement.

Undertaking the verification

The duty holder engages a consultant to complete the HA. The duty holder provides the environmental auditor a draft HA for comment. The environmental auditor provides comment on the draft HA. The duty holder (and their consultant) finalises the HA and shares it with the environmental auditor for review.

The environmental auditor uses a checklist to systematically review the HA for data quality, sources, consistency, accuracy and compliance with regulations. The environmental auditor fills out the HA checklist from Publication 668: Hydrogeological Assessment (Groundwater Quality) Guidelines (668.1).

Writing the verification report

The environmental auditor fills out the table below.

The environmental auditor critically evaluates the conceptual hydrogeological model and the risk assessment. This is to determine if they are adequate for assessing the risk of harm. This does not require the environmental auditor to conclude whether there is a risk of harm. Instead, it determines whether sufficient hydrogeological work has been completed or recommended.

In conclusion, the environmental auditor states:

• Based on the environmental auditor’s assessment as detailed within this verification report, the environmental auditor verifies that the ‘CS Environmental, 2025, Hydrogeological Assessment, 4 Perfect Parks Ave, Undertown, VIC’ meets the requirements of EAN-0000XXXX. Based on the environmental auditor’s review, the HA appears to support that risk is appropriately understood, or that otherwise, recommendations have been made to address data gaps.
• The environmental auditor notes that CS Environmental has recommended the installation of an additional groundwater well and minor update to the monitoring required by the RMMP. The environmental auditor recommends that the next environmental auditor verification of the RMMP includes consideration of whether these recommended updates have been incorporated.

Submitting the verification report

The environmental auditor includes the following attachments for completeness:

• Appendix A - Hydrogeological assessment checklist
• Appendix B – Current EPA Notice
• Appendix C - Hydrogeological Assessment Report
• Report coversheet:

The environmental auditor provides the completed verification report to the duty holder. The duty holder emails the verification report to the EPA authorised officer who issued the environmental action notice.