Environment, Health & Safety (EHS) Audit: What Cannabis Businesses Should Do After the Audit
By Michelle Bodian, Jace Pohlman
May 2, 2022
Environmental, Health, and Safety (EHS) audits can come in many varieties: regulatory agency inspections (scheduled or surprise), internal company requirements, maintenance of certifications, or during an acquisition or sale. In the three-part series so far, we’ve looked at ways for your business to prepare for an audit as well as what to expect on audit day. In this final article, we will dial in on what to do after the audit.
So, the auditor wrapped up the cannabis facility tour and review of business records... Now what happens?
Audit Debrief
After the audit, the auditor will likely hold a debrief or closing meeting with management covering the audit’s findings, any infractions, and ways to fix non-compliant practices. This meeting is important because it not only shows you what corrective actions your business needs to take, but also provides a chance for you to ask the auditor questions. Here are a few tips for the audit debrief stage:
Tips for Audit Debriefs
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Have key company personnel present for the meeting (in person or via telephone) to understand the first impression results and ask questions about next steps (including timing)
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Ask for a verbal summary of the findings or other form of the results page to keep on file as well as a record of the next steps for the business to take
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Use the debrief to clarify misunderstandings and interpretations of certain requirements. This is a chance to make sure any corrections being done are exactly what the auditor (likely a government agency) would want
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Don’t argue the auditor’s findings. There will be chances for appeals or arguments later. Immediately after the audit is not the time
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Lastly, it’s important to take your time. Audits can be long and it’s understandable to want this final step done quickly. However, don’t let that get in the way of asking questions, clarifying the auditor’s findings, or providing additional color around your operations
Resolve Identified Gaps in Compliance or Deficiency
While this may seem obvious, if an internal or external audit identifies any areas of non-compliance it’s crucial to resolve these issues in a timely manner. Not all issues identified are created equally, however. In order to effectively deploy staff and resources, the company could rank areas of non-compliance according to priority. Working towards resolving gaps in compliance in small manageable tasks will make the process less daunting.
Use Audit Results for Future Compliance
Audit results also provide the framework for maintaining EHS compliance going forward. Businesses can use the auditor’s findings and suggestions to create new operating procedures that create an environment of accountability and compliance.
Implement Internal Audits
One tool for achieving accountability is through internal audits. These serve as checks on the business at scheduled times to make sure everything is prepared come audit time. For example, if there is a highly regulated part of a facility, it may be helpful to use internal audits throughout the year to make sure the operations and personnel of that department are prepared.
Track Regulatory Requirements
Businesses can also develop a type of findings report that allows the tracking of certain regulatory requirements throughout the year. These reports may include the following:
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Summary of the previous audit, including any infractions or issues the auditor noted
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Local/state/federal regulatory requirements
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Identifying responsible parties, individuals, and corrective actions to be taken in certain situations
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Weekly compliance checks and results
The point is to identify aspects of the business that are subject to compliance requirements and develop a way to track whether requirements are met through continuous checks.
Personnel Education & Training
Another important part of maintaining compliance is through educating employees on regulatory requirements. Having monthly or even quarterly training exercises can keep employees up to speed on changes in the law. Even sending a weekly email with notable updates on regulatory requirements or audit topics can keep important personnel up to date.
Creating a Culture of Compliance
Fixing an infraction found through an audit is only one piece of the EHS compliance audit puzzle. Taking the audit results and creating a culture of continuous compliance through internal reporting and training shows that your business is committed to creating a better environment for consumers, employees, and the world.
We hope this series helped you to better understand, plan for and react to EHS audits in the cannabis industry.
If you have questions or need guidance on implementing Environmental, Health, and Safety practices at your cannabis business, don’t hesitate to reach out to a member of VS’s EHS team.