Environmental, Health & Safety (EHS) Audit: What Cannabis Companies Should Do After the Audit | Vicente Sederberg LLP – Advice Eating

[co-author: Jace Pohlman]

Environmental, health and safety (EHS) audits can come in many forms: inspections by regulatory bodies (planned or unexpected), internal company requirements, maintaining certifications, or during a purchase or sale. In the three-part series so far, we’ve looked at how your company can prepare for an audit and what to expect on the day of the audit. In this final article, we’ll dial in on what to do after the audit.

So, the auditor has completed touring the cannabis facility and reviewing the business records… What happens now?

Audit Debriefing

After the audit, the auditor will likely hold a debriefing or closing meeting with management to discuss the results of the audit, any violations, and ways to address non-compliant practices. This meeting is important because it not only shows you what corrective actions your company needs to take, but also gives you the opportunity to ask the auditor questions. Here are a few tips for the audit debriefing phase:

Tips for audit debriefings

  1. Have Key company personnel present at the meeting (in person or over the phone) to understand first impression results and ask questions about next steps (including timing).

  2. ask for one oral summary of results or some other form of results page to be retained and a record of the next steps the business needs to take

  3. Use the debriefing to do this clear up misunderstandings and interpretations of certain requirements. This is an opportunity to ensure that any corrections made are exactly what the auditor (likely a government agency) wanted

  4. Do not contradict the examiner’s findings. There will be opportunities for objections or arguments later. Immediately after the audit is not the time

  5. Finally, it is important take your time. Audits can be lengthy and it is understandable that this last step should be done quickly. Don’t let that stop you from asking questions, explaining the auditor’s findings, or adding additional color to your operations

Resolve identified compliance gaps or deficiencies

While this may seem obvious when an internal or external audit identifies areas of non-compliance, it is central to solve these problems in a punctual. However, not all identified problems are created equally. To allocate staff and resources effectively, the organization could prioritize areas of non-compliance. Fixing compliance gaps 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. Organizations can use the auditor’s insights and suggestions to create new operating procedures that create an environment of accountability and compliance.

Implement internal audits

One tool to achieve accountability is internal audits. These are designed to review the store at set times to ensure everything is prepared at the time of the audit. For example, if there is a highly regulated part of a facility, it can be helpful to conduct internal audits throughout the year to ensure that the operations and staff of that department are prepared.

Track regulatory requirements

Companies can also develop some sort of findings report that allows tracking specific regulatory requirements throughout the year. These reports can include:

  • Summary of the previous audit including any non-compliances or issues identified by the auditor

  • Local/state/federal regulatory requirements

  • Identification of responsible parties, individuals and corrective actions to be taken in specific situations

  • Weekly compliance checks and results

It’s about identifying aspects of the business that are subject to compliance requirements and developing a way to track compliance through continuous audits.

staff training and education

Another important part of maintaining compliance is educating employees about regulatory requirements. Monthly or even quarterly training sessions can keep employees up to date on changes in the law. Even sending out a weekly email with notable updates on regulatory requirements or audit topics can keep key employees in the know.

Creation of a culture of compliance

Resolving a breach found through an audit is only one piece of the EHS compliance audit puzzle. Audit results and the creation of a culture of ongoing compliance through internal reporting and training show that your company is committed to creating a better environment for consumers, employees and the world.

We hope this series has helped you better understand, plan for, and respond to EHS audits in the cannabis industry.

Read part 1 of the series: Environmental, Health & Safety (EHS) Audit: How Cannabis Businesses Can Prepare

Read part 2 of the series: Environmental, Health & Safety (EHS) Audit: Tips for Cannabis Businesses on Audit Day

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