Environment, Health & Safety (EHS) Audit: How Cannabis Businesses Can Prepare

By Michelle Bodian, Jace Pohlman

Apr 7, 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. Even with a scheduled audit, stress will run high. Although the best preparation for an audit is yearly preparation, there are some ways you can prepare right before the audit.

In this three-part VS Insights series, we will walk through an EHS audit from pre-audit to post-audit, providing tips and tricks along the way.  

Pre-Audit Preparation

Why Perform an Internal Audit? 

Internal audits allow your business to ensure compliance with many different EHS regulations that protect workers as well as the surrounding land and community. In addition, internal audits are a chance for cannabis businesses to improve in areas they may not have considered, including creating a culture of compliance amongst employees and management.

Audits also allow cannabis businesses to stay up to date on the legal requirements for their business. This is particularly important in the cannabis industry, where rules and laws can change daily. Lastly, and perhaps most importantly, having a consistent audit schedule can help your business avoid regulatory fines for non-compliance and save money from correcting deficient operations.

Why Might a Cannabis Facility Receive an Outside Audit? 

Various federal, state, and local agencies have jurisdiction over cannabis agencies. Those EHS-related agencies include the following:

  • OSHA (Occupational Safety and Health Administration) – protects workers
  • EPA (Environmental Protection Agency) – federal environmental agency
  • State environmental agencies

What Areas of Focus Will an EHS Audit Include?  

  • Air quality
  • Risk assessments
  • Spill prevention and control
  • Emergency planning – fire safety
  • Industrial hygiene
  • Solid and hazardous waste
  • Water discharges
  • Air emissions – emergency generator, solvents
  • Storage tanks
  • Chemical reporting
  • Powered industrial vehicles
  • Hazard communication
  • Personal protective equipment
  • Fire protection – flammables storage
  • Respiratory protection

This list does not include all types of audits. Single audits frequently cover multiple topics.

Pre-Audit Tips

  • Determine the Scope

    • Is the audit a regulatory agency inspection of your water treatment plan or a compliance check for worker safety? Knowing why your business is being audited will clarify what business records and information may be needed. It will also help prevent scrambling to prepare documents and files for the auditor.

  • Stay Prepared

    • Keeping business records and files easily accessible and maintaining multiple copies of reports and submissions will make it easier for the auditor and give you peace of mind.

  • Inform Personnel

    • Not all personnel need to be involved in an audit, but it’s important to explain to staff why people are wandering through the facility and how they should respond to questions if an auditor approaches them.

  • Stay “Audit-ready”

    • Maintain information on audit topics and operations throughout the year, so surprise audits are no sweat. Doing so will improve reliability in the records and build relationships with the auditors by having the required information available for them quickly and efficiently.

Audit day can be a stressful experience for all involved. We hope these preparation tips give you an idea of what auditors are looking for and how to have your cannabis business as ready as possible.

Read part two of our EHS audit series, where we cover the details of an audit day and what cannabis businesses should expect when they let the auditor through their door.

Please reach out to VS EHS practice leader Michelle Bodian with any questions or comments.

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