The 2016 Environmental Audit Season is Underway
In 1997, the Department of the Interior (DOI) mandated that DOI bureaus, including the NPS, develop and implement an environmental auditing program for “all lands, facilities, and operations.” The NPS interpreted this directive to include NPS concessioners, and in 1999, Commercial Services established an environmental audit program geared specifically towards concessioner programs.
The purpose of the NPS Commercial Services environmental audit program is to:
- Help concessioners comply with applicable environmental requirements.
- Promote sustainability.
- Recognize and implement best management practices (BMPs).
- Recognize exceptional practices that demonstrate environmental stewardship and management.
- Recommend corrective actions and compliance assistance resources to concessioners.
Audits occur every three to five years and the audit process begins with scheduling concession audits. Preparation for each audit site visit includes:
- Contacting the region, park, and concession staff.
- Collecting pre-visit data.
- Confirming the audit scope.
- Arranging audit logistics.
- Conducting pre-visit final preparations.
Once pre-visit activities are complete, the site visit occurs. The site visit is the most thorough portion of an environmental audit, and it is during this phase that the audit team has the most interaction with concession and park staff. The audit team works to understand each concession’s compliance issues and to identify BMP opportunities, while sharing knowledge with concession and park personnel on environmental issues and corrective action opportunities.
Auditors conduct interviews with concession staff to gather information on concession facilities, services, and operations. Auditors review concession records and documents to:
- Assess compliance with current applicable laws and the concession contract.
- Understand the concessioner’s Environmental Management Plan (EMP), if applicable.
- Verify the issues identified by interviews or observations.
Audit findings are developed when the audit team concludes that concession operations are not in compliance with audit criteria. Audit findings are assigned a 1, 2 or 3 priority level:
- Priority 1 audit findings represent non-conformance with laws and regulations that pose immediate actual or potential harm to human health or the environment, or the potential for significant liability.
- Priority 2 audit findings represent non-conformance with laws and regulations that do not pose an immediate threat to human health or the environment.
- Priority 3 audit findings represent non-conformance with DOI, NPS, or park policy, or the concession contract that do not pose an immediate threat to human health or the environment.
Post-visit activities include a Preliminary Audit Report and a Final Audit Report. Auditors prepare the Preliminary Audit Report based on data collected in the field. The Preliminary Audit Report includes applicable audit findings and exceptional practices. Exceptional practices are products used or activities undertaken that are not often seen at park concession operations. They also demonstrate a concessioner’s commitment to environmental protection beyond compliance. Park staff will have the opportunity to read and comment on the Preliminary Audit Report before the Final Audit Report is created and distributed.
Commercial Services staff are currently developing the 2016 Audit Schedule. Once the schedule is finalized, Commercial Services staff will reach out to park staff where audits are scheduled to occur. Commercial Services staff and park staff will determine the appropriate dates and times for the audits and park staff will confirm dates with their concessioners.
For more information, please contact Sue Straw via email or directly at 303.987.6921.