1. A Graduate Report on
Environmental Audits
For the Course of
‘Sustainable Urban Planning Practices (CE-632)’
of the M.Tech (I) Sem-2 of Urban Planning
Submitted by: Yajush G. Sonar (P17UP010)
Faculty Advisor: Dr. J.E.M. Macwan
P.G Section (Urban Planning),
Department of Civil Engineering,
सरदार वल्लभभाई रा�ीय �ौ�ोिगक� संस्थान, सूरत
Sardar Vallabhbhai National Institute of Technology
Surat, Gujarat
(2017-2018)
2. CERTIFICATE
This is to certify that a Graduate Report on “Environmental Audits” submitted by me has
satisfactorily completed the requirement for the Subject CE: 632 – Sustainable Urban
Planning Practices during the year 2017-18.
Yajush G. Sonar (P17UP010)
Faculty Advisor,
Dr. J.E.M. Macwan
P.G Section (Urban Planning),
Department of Civil Engineering,
सरदार वल्लभभाई रा�ीय �ौ�ोिगक� संस्थान, सूरत
Sardar Vallabhbhai National Institute of Technology,
Surat, Gujarat
(2017-2018)
3. Environmental Audits
ACKNOWLEDGEMENT
I earnestly wish to express my heartfelt thanks and a sense of gratitude to Dr. J.E.M. Macwan
for his valuable guidance and constant inspiration in preparing this report. I also acknowledge
the inspiration and encouragement provided by him. Frequent interactions with him in all
aspects of the report making have been a great learning experience. I shall always cherish his
support and encouragement.
YAJUSH G. SONAR
4. Environmental Audits
CONTENTS
1. Introduction
1.1. Introduction
1.2. Objectives
1.3. Existing Indian Scenario
2. Environmental Auditing
2.1. Components
2.2. Frame work of Environmental Audit
2.3. Categorisation of Environmental auditing
2.4. Steps followed for Environmental Auditing
2.5. Applicability of the scheme
2.6. Environmental Auditing process
2.7. Audit Report
2.8. Format of audit report
2.9. Consequences of failure to file audit report
2.10. Accountability/liability of the auditors/Industries
Proforma 1: Format of Environmental Audit Report
References
5. Environmental Audits
CHAPTER 1
INTRODUCTION
1.1. Introduction:
Environmental auditing is a management tool designed to provide information on
environmental performance to the right people at the right time. This audit encompasses all
kinds of activities related to environmental measures of an organisation.
According to the World Bank, environmental audit is a methodical examination of
environmental information about an organization, a facility or a site, to verify whether, or to
what extent, they conform to specified audit criteria. The criteria may be based on local,
national or global environmental standards. Thus, it is a systematic process of obtaining and
evaluating information about environmental aspects. In view of the increasing importance
assigned to environmental issues and sustainable development, both at the national and
international level, environmental audit has gained substantial currency and materiality. The
allocation of substantial amounts of public funds for implementing environment programmes
and schemes in the annual budgets enhances the scope of environmental audit.
Environmental audit is a highly skill-oriented task. It calls for not only a high level of
professional audit skills, but also a deep understanding of environmental issues. The
environmental auditor must also be familiar with international treaties and conventions on
environmental issues apart from having an excellent grasp of the national policy, strategies
and programmes for environmental protection and conservation and climate change control.
Since this is an emerging area, the auditor will also have to periodically update himself with
the latest developments on the subject, nationally as well as internationally.
• Auditor: shall mean Environmental auditor recognized by the GPCB.
• Environment Audit Report: shall mean Environment Audit Report required to be
submitted under the Scheme in the prescribed format.
• Audit Team: An Audit team shall consist of 4 members in the form of an
Environmental Engineer, Chemical Engineer, Chemist and Micro Biology/Bio-
6. Environmental Audits
Chemistry or Chemistry or Biotechnology or Zoology or Environment Science or
Climate Change or Forensic Science or Life Science.
• Association of Industries: shall mean Association of Industries in the concerned
estate/area where a particular industrial unit is situated.
• Environment Audit Committee: An expert technical committee as Environment Audit
Committee constituted by GPCB from the inception of the scheme for implementation
of recognition procedure for the auditor in context with the environment audit scheme
and to recommend GPCB for the same. In addition to this, Environment Audit
Committee provides advice/guidance/technical input related to the subject. As per the
scope of work, committee members periodically visit the auditor's laboratories and
advice them in this matter and will suggest/implement the new parameters which are
being introduced by the CPCB/GPCB. (Annexure- A)
• Environmental Management System: shall include treatment plants, equipments and
processes for liquid effluents, air emissions, noise, solid wastes and other pollutants.
Also collection, treatment, conveyance and disposal system for such wastes and other
pollutants.
• Schedule: means schedules of the environment audit scheme.
• Specified Industries: shall mean industries manufacturing/processing any one or more
of the products mentioned in Schedule I or Schedule II.
• Specified Product: shall mean products/processes specified in Schedule I or Schedule
II of this Scheme.
1.2. Objectives:
1. To see that the natural resources are properly utilised.
2. To control the costs incurred on procuring the natural resources and to ensure that
they have been properly classified.
3. To see that natural resources have been properly shown in balance sheet as they are
the nation’s valuable assets.
4. To ensure that the natural resources are utilised for industrial development and for
national progress.
5. During production processes when natural resources are utilised, some adverse
environmental effects are produced and pollution is created. So the objective of such
7. Environmental Audits
an audit is to see that proper steps have been taken to control or to prevent such
adverse effects like pollution.
6. To see that proper steps have been taken for maintaining health and welfare of the
community and also for disposal of harmful wastes and social risk.
1.3. Existing Indian Scenario:
The concept of environmental auditing in industrial units in India was formally introduced in
March 1992 with the overall objective minimising consumption of resources and promoting
use of clean technologies in industrial production to minimise generation of wastes. A series
of discussions were held among the concerned regulatory agencies before and after making
environmental auditing and submission of Annual Environmental Statements, a mandatory
requirement for the industries. This followed organisation of a number of workshops,
seminars and training programmers all over the country by different agencies dealing with
environment protection, conducting of audit studies in 125 selected polluting industries in the
country by the Central Pollution Control Board (CPCB), Delhi, and a number of other
activities.
Aspects covering details of the activities before and after the introduction of this requirement
in the country,
(i) the evolution of the concept,
(ii) the history of the introduction of the scheme in the country and the organisational
structure,
(iii) the mandatory requirement and its applicability,
(iv) the implementing agencies and their responsibilities,
(v) summary of the training programmes/workshops organised in the country,
(vi) case studies conducted by CPCB in selected polluting industries and the major findings,
(vii) development of guidelines for conducting environmental audit in different categories of
polluting industries, and
(viii) the current status of the scheme and plans for its effective implementation.
8. Environmental Audits
India is the first country in the world to make environmental audits compulsory. The
government of India, by its gazette notification [No. GSR 329 (E)] of March 13, 1992, made
it mandatory for all industries to provide annual environmental audit reports of their
operations, beginning with 1992-93. This required industries to provide details of water, raw
materials and energy resources used, and the products and wastes generated by them. These
audit reports were to be submitted to the concerned State Pollution Control Boards or before
September 30 every year.
This scheme was expected to promote proper monitoring of industrial activities, adoption of
low cost technology and minimisation of resource consumption. But though it has been in
force for more than two years it has not made much headway. Out of the lakhs of industries
that exist in India, only 2,995 audit reports were filed by December 1993. It has also become
obvious that the deadline of September 30 is not adhered to. Due to widespread non-
compliance, this deadline has been extended a number of times.
Champions of this regulation feel that the government has adopted a proactive approach to
the conservation of natural resources, instead of observing the usual command and control
method. Its critics feel that this notification was hurriedly implemented without the prior
creation of necessary infrastructure/experts which would enable its appropriate
implementation.
This novel concept of environmental audit was distorted, surprisingly, by the government,
when on April 22, 1993, by a revised notification [No. GSR.386 (E)] the term Audit Report
was replaced by Environmental Statement. This change inevitably toned down the impact of
the regulation.
The industries were now to fill a form and submit it to the concerned Pollution Control
Boards (PCBs). It made it easy for industries to make statements to the effect that they have
taken the requisite steps in compliance with existing pollution control regulations. These
statements might not be based on actual audit reports. If this becomes a rule, the whole
purpose of the environmental audit regulation would be defeated.
Industries have a list of grouses against environmental audits. They are opposed
environmental audits. They are opposed to the disclosure of their modus operandi to the
public, who they feel are not mature enough to follow the importance of such data. They fear
it would lead to legal wrangles and litigation and that the data would be used by Pollution
9. Environmental Audits
Control Boards for prosecution. Publishing details of raw materials used and processes might
reveal their trade secrets.
Another factors which hampers environmental audits in India is the lack of specialised
environmental auditors. Only three or four agencies exist which are qualified to conduct
environmental audits. The setting up of an institute of environmental auditors like the
Institute of Chartered Accountants of India, would have been an apt preamble to the adoption
of this regulation.
Moreover, small industries cannot afford to hire the services of existing environmental audit
agencies. First time environmental auditing will cost an industry between Rs.75,000 to
Rs.200,000 and 15 months to complete.
The Pollution Control Boards have no follow up plans. The reports submitted are not double-
checked to find out whether the forms hold the correct data. One report has been examined
and acted upon till date. The industries do not get any feedback.
An environment audit programme, if designed and implemented conscientiously, can enhance
an industry’s environmental performance. If an industry sets up its own system in
compliance with existing laws, then conducting audits would be a normal and considerably
easier procedure. It will expose problems that require action. It improves the material and
energy efficiency of production processes, conserves resources, minimises wastes, provides
direct economic benefits to the industry and stimulates growth of the industry as well as the
national economy.
Despite the above most industries are apprehensive about audit reports since pollution control
boards are regarded by them more as an enforcer, a policeman, than as an advisor. The
government has to assure them that an audit report will not be used to instigate prosecution or
litigation.
There is yet another angle to this gamut of environmental auditing. We know that industries
can be taken to court if prescribed pollution limits are exceeded. But after submitting this
audit statement the industries may contend that they cannot be sued since their audit report
has been accepted by the SPCBs. Does the government have any way to counter this?
10. Environmental Audits
Environmental audits are vital not just for a clean environment but also because their use is
the best way to correct different problems detected at their source and to minimize wastes and
foresee conservation and maintenance measures needed to prevent major pollution problems.
Industries in developed countries conduct audits as part of their overall drive for quality
assurance to establish a “green edge” over competitors in environmentally sensitive markets.
Moreover, green audits are asked for by investment banks before they pour in money. With
the Indian economy opening up, industries have no option but of go green if they want to
remain in the race.
11. Environmental Audits
CHAPTER 2
ENVIRONMENTAL AUDITING
2.1. Components:
1. Full management commitment.
2. Audit team objectivity.
3. Professional competence.
4. Well defined and systematic approach.
2.2. Frame work of Environmental Audit:
The Supreme Audit Institution of India through its various field offices has been conducting
compliance audit of government laws, rules and legislations as well as performance audit of
government programmes and schemes.
Environmental audits have been conducted by SAI India for the last 25 years. This process
was formalised with the introduction of specialized guidelines {MSO (Audit) 2002} for
conduct of environmental audits. This laid down broad guidelines to enable SAI India’s
auditors to examine whether the auditee institutions gave due regard to the efforts of
promulgating sustainability development and environmental concerns, where warranted.
With a view to bring in a focused attention and consolidate the approach for better outputs
and infusing new techniques and tools, SAI India designated the office of the Principal
Director of Audit (Scientific Departments) as the nodal office for Environmental Audit. This
office undertakes exclusively, environmental audits of central government programmes, all
over the country.
A Regional Training Institute in Mumbai has been designated as the nodal training center to
impart training to officers and staff of SAI India on environmental auditing.
As a result of having a specialized office and a training institute, SAI India has a vast pool of
audit professionals equipped with techniques of environmental auditing.
SAI India has conducted more than 100 specialised environmental audits over the last 25
years.
1. Financial Audit:
12. Environmental Audits
The objective of financial audit is to enable the auditor to express an opinion on
whether the financial statements are prepared in all material respects in accordance
with an identified financial reporting framework. Material respects can be directly
linked to the environmental costs, obligations, impacts and outcomes. The audit of
financial statements also requires the auditor to consider environmental matters as
part of regularity audit.
2. Regularity and Compliance Audit:
The objective of regularity audit is to assess the completeness and accuracy of the
information and data provided. In compliance audit, the objective will be to provide
an assurance that governmental activities are conducted in accordance with relevant
environmental law, regulations, standards and policies, both at the national and local
levels as well as international levels (where appropriate and relevant).
3. Performance Audit:
The objectives of performance audit are manifold and may include ensuring that
indicators of environmental related performance (where contained in accountability
reports) fairly reflect the performance of the reported entity. Further, the audit verifies
that the environmental programmes are conducted in an economical, efficient and
effective manner. It also aims at improving the performance and accountability of
government agencies and bodies by adding value through an effective examination of
environment-related policies, strategies and programmes. Apart from verifying the
extent to which the programme has achieved its objectives, the performance audit will
also examine the intended and unintended, direct and indirect other impacts of
programmes and activities subjected to audit as also the adequacy of data for
evaluating such impacts. Identification of risks caused by pollution to health and
environment would also form part of such exercise. Performance audit of
environmental issues will also include the existence or adequacy of environmental
policies and laws and strategies. Other objectives would include the compliance with
commitments, if entered into or legally obligated, with international treaties and
commitments, where applicable. Adequacy of infrastructure to achieve the
environmental targets of the agency and adequacy of funding will also be the subject
of performance audits.
13. Environmental Audits
2.3. Categorisation of Environmental auditing:
1. A technical review:
Such an audit will involve the systematic collection of information about the existing
and potential impact of the organisation’s activities on the environment; it will
normally cover compliance with pollution control and waste management legislation.
It will not cover management practices.
2. A management review:
This will focus more on the management procedures and record- keeping and will
also gather information on compliance with legislation. It may also review procedures
in the context of company policies, programmes and other requirements. It will not
examine the existing or likely impact of the operation on the surrounding environment
from a technical standpoint.
3. Due diligence review:
This will examine the likely cost of implementing pollution control and site
remediation actions and will take account of existing and future legislation. Such
liability reviews are normally carried out in the context of mergers, acquisitions and
long range company planning.
2.4. Steps followed for Environmental Auditing:
a) Planning of the audit activities, including definition of responsibilities for the audit;
b) Review of the environmental protection policy of the company:
c) Assessment of the organisation, management and equipment;
d) Gathering of data and of all relevant information;
e) Evaluation of the overall performance;
f) Identification of areas for improvement;
g) Internal reporting to the top management;
14. Environmental Audits
2.5. Applicability of the scheme:
1. This Scheme shall apply to all the industrial units manufacturing and/or processing
any one or more of the products mentioned in Schedule I and/or Schedule II to this
Scheme, and situated in the State of Gujarat.
2. Any product the manufacture of which consumes the same or substantially the same
raw materials consumed for the manufacture of any of the aforesaid mentioned
items/products is same or substantially similar, shall also be considered to be a
specified product within the meaning of this Scheme.
3. An industrial unit which is manufacturing or processing any of the specified products
under orders of trial production (whether passed by Honourable High Court or any
authority) is also covered by this Scheme.
4. All common facilities i.e. CETPs /TSDFs/CBWTFs, common Hazardous waste
Incinerator, Common Spray Dryer, E-waste and other common facilities etc of the
state. All other industries manufacturing products which are included by the Board in
Schedule I or Schedule II as per specified product list.
2.6. Environmental Auditing process:
a) Pre- Audit Activities:
i. Select and schedule facility to audit based on:
15. Environmental Audits
• Selection criteria
• Priorities assigned.
ii. Select audit team members:
• Confirm their availability
• Make travel and lodging arrangements
• Assign audit responsibilities.
iii. Contact facility and plan audit:
• Discuss audit programme
• Obtain background information
• Administer questionnaire (if necessary)
• Define scope
• Determine applicable requirements
• Note priority topics
• Modify or adapt protocols
• Determine resource needs
• Identify facility staff to be interviewed, confirm availability.
b) Activities at site:
i. Identify and understand management control systems:
• Review background information
• Opening meeting
• Orientation tour of facility
• Review audit plan
• Confirm understanding of internal controls.
ii. Assess management control systems:
• Identify strengths and weaknesses of internal controls
• Adapt audit plan and resource allocation
• Define testing and verification strategies.
16. Environmental Audits
iii. Gather audit evidence:
• Apply testing and verification strategies
• Collect data
• Ensure protocol steps are completed
• Review all findings and observations
• Ensure that all findings are factual
• Conduct further testing if required
• Liaise with regulatory authorities.
iv. Evaluate audit findings:
• Develop complete list of findings
• Assemble working papers and documents
• Integrate and summarise findings
• Prepare report for closing meeting.
v. Verbal report of findings to facility:
• Present initial findings at closing meeting
• Discuss findings with plant personnel.
c) Post-audit Activities:
i. Issue draft report
• Corrected closing report
• Determine distribution list
• Distribute draft report
• Allow time for corrections.
ii. Issue final report
• Corrected draft report
• Distribute final report
• Highlight requirement for action plan
• Determine action plan preparation deadline.
17. Environmental Audits
• Action plan and preparation and implementation
• based on audit findings in final report.
d) Carrying Out the Audit:
i. Collecting Information:
Environmental auditing requires the auditor to develop a full understanding of the
controls, procedures and practices that are in place or are thought to be in place. These
are likely to include formal procedures and practices; all forms of records (including
monitoring); existing inspection and maintenance programmes; physical controls and
other measures to contain spills and other incidents, etc.
The auditor will need to understand how responsibilities are defined; how personnel
are trained and how competent those on the site appear to be; how procedures are
carried out and other standard management issues.
In addition to the use of the detailed questionnaire (forming part of the protocol) the
auditor will gain information through observation, interviewing individual staff,
reviewing specific documentation and speaking to the appropriate regulatory
authorities.
ii. Audit Interviews:
Since interviewing is one of the primary techniques used in gathering audit
information, good interviewing skills are essential to the successful completion of the
audit. Attention to the following elements of interviewing skills during the audit
process will assist in establishing a good rapport with the facility personnel as well as
obtaining the information required:
Take notes during the interview and record the name, title and job description of the
person interviewed; be alert and responsive to the interviewee when asking questions
and listening to responses; control the interview, but ensure that you appear relaxed
and that your interviewee feels relaxed; go to the interviewee’s workplace/office
where possible; plan the interview so that you introduce yourself, explain the purpose
of the interview and gather the appropriate information; know when to end the
interview and thank the interviewee; end the interview on a positive note.
18. Environmental Audits
iii. Documentation:
It is a central principle that the audit should be fully documented; there should,
therefore, be a clear, written, audit trail. The working papers from an audit will
include completed protocols, associated questionnaires, auditor notes and copies of
documents collected during the audit itself.
It is important that each auditor ends the audit with a complete set of field notes and
papers for each protocol step assigned to that auditor; that there is documentation:
(1) To ensure that an adequate audit was conducted and,
(2) To substantiate compliance and non-compliance issues, both with respect to
regulatory requirements and company procedures; that there is a record of reference
copies of documents collected during the audit; and there is the data to support the
audit report, which may be helpful in subsequent follow-up.
The working papers should, therefore, contain all the information that the auditor
believes may be necessary to support the audit findings and should contain a
description of environmental management and control systems—including flow
charts, diagrams, copies of documents, etc.; a description of the action taken to
complete each step of the audit protocol; details of answers to questions in the
protocol and other questionnaires used; details of any ‘tests‘ conducted during the
audit (e.g., checking that consignments of hazardous waste had the relevant
documentation for each disposal).
iv. Public Disclosure:
Unlike financial audits, environmental audits are not carried out for the purposes of
providing information to the regulatory authorities or the public at large. They are
intended to assist management understand the impact their operations are having upon
the environment and to provide a basis for taking action to remedy any problems.To
this extent companies are likely to be unwilling to make the results of their
environmental audits public; or, if the audit is carried out with this objective, it is
likely that it will be a far less valuable management tool.
The ICC (Indian Chamber of Commerce) has noted that if environmental audits are to
be successfully used as part of company policy ‘it is essential that the procedure
should be seen as the responsibility of the company itself, should be voluntary and for
company use only’.
19. Environmental Audits
The Eco-Audit proposal does however propose that certain information should be
made available to the public on the environmental performance of the company. This
would be an ‘environmental statement’ specific to each site audited and prepared with
the same frequency as the environmental audits.
2.7. Audit Report:
a) Contents of the Report :
Each of the specified industries shall submit to the GPCB, audit report/s in triplicate
regarding adequacy and efficacy of its Environmental Management Systems for its
products in the light of,
i. Statutory requirements as under:
• The Water (Prevention and Control of Pollution) Act, 1974
• The Air (Prevention and Control of Pollution) Act, 1981
• The Environment Protection Act, 1986
• The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989
• The Rules for the Manufacture, Use, Import, Export and storage of Hazardous Micro-
Organisms/Genetically Engineered Organisms or cells, 1989
• The Chemicals Accidents (Emergency Planning, Preparedness and response) Rules,
1996
• The Bio-Medical Waste (Management & Handling) Rules, 1998
• The Noise Pollution (Regulation & Control) Rules, 2000
• The Ozone Depleting Substances (Regulation & Control) Rules, 2000
• The Municipal Solid Wastes (Management & Handling) Rules, 2000
• The Hazardous Wastes (Management, Handling and Trans boundary Movement)
Rules, 2008
• The Plastic Waste (Management & Handling) Rules, 2011
• The E-waste (Management & Handling) Rules, 2011
ii.
• The terms and conditions of the letter of Consent/NOC issued by the GPCB
20. Environmental Audits
• Other conditions which the GPCB may stipulate by any general order or circular or in
any special order for a class of industries or for the particular industrial unit
concerned.
iii. Relevant literature published by CPCB, GPCB and other authoritative literature on the
subject.
iv. Inspections and monitoring made by the auditor, composite samples collected by the
auditor for running batch/ batches and samples collected on surprise visits including
samples collected at different stages of effluent treatment and their analysis reports
prepared by the Auditors.
v. Figures of production of products, by products, consumption of raw materials, figures
regarding use of water, electricity and other fuel and other material mentioned in the
format of the Environmental Audit Reports prepared by the Auditors.
vi. Complaint, if any, received by the GPCB or the Auditor.
vii. Orders, if any, passed by the Court, in respect of any specified product and or industry
or class of specified industries.
b) Submission of Reports:
All common facilities i.e. CETPs /TSDFs/CBWTFs, Common Hazardous Waste
Incinerator, Common Spray Dryer, E-waste and other common facilities etc. shall
have to submit environment audit report half yearly and remaining industries falling
in Schedule- I or II category of specified products list shall have to submit
environment audit report yearly. Copies of each audit report shall be submitted by
specified industry to Gujarat Pollution Control Board, Gandhinagar. (in triplicate with
adequate fees).
c) Time Schedule:
The audit reports shall be submitted by each specified industry by 30th June every
year with adequate fees to GPCB.
21. Environmental Audits
d) Scrutiny fees:
All the specified industries shall ensure that environmental audit report prepared by
the auditor is to be submitted with scrutiny fee of Rs.20,000/- (Rupees Twenty
thousand only) for industry falling in Schedule I, and Rs.10,000/- (Rupees Ten
Thousand) for industry falling in Schedule II, by Demand Draft in favour of GPCB
Gandhinagar at the time of submitting to GPCB. If industries having valid ISO 14001
accreditation, the half of the fees shall be payable.
e) New/ proposed industries:
All the industries & common facilities covered under Schedule I and Schedule II
which may be set up in any month during a particular year shall submit EARs for a
period up to 31st March of the next year; e.g. if an industry/common facility starts its
production/operation in August'15, then it shall prepare EARs through recognized
auditor for a period of August'15 to 31st
March'16 (even though it may be on trial run)
and must submit EAR before 30th June'16, with necessary scrutiny fees.
23. Environmental Audits
2.8. Format of audit report:
The auditor shall submit environment audit report in prescribed format with the following
Details,
a) Whether the industry meets with the requirements laid down by or under the aforesaid
statutory provisions, if no, the extent of deviation from the norms;
b) Whether the industry has complied with the terms and conditions of the Consent/NOC
issued by GPCB in favour of the Unit with reference to each term and condition;
c) Whether the industry has complied with the terms and conditions of any general or
special circular/order of the GPCB;
d) Whether the industry has taken measures for safety and for prevention of health
hazards to the labour employed in the specified industries including their working
conditions, and whether the industry has complied with the relevant provisions of the
Factories Act and the Rules made there under. For this purpose, the auditors shall take
into consideration the Proforma Statement to be prepared by the Labour
Commissioner and the Chief Inspector of Factories in consultation with the National
Institute of Occupational Health.
It shall be open to the auditors to make such recommendations as they may think fit for
improvement of the existing Environmental Management System but such recommendations
shall not bind the GPCB in any manner.
2.9. Consequences of failure to file audit report:
If any specified industry (industry falling in Schedule I and Schedule II of the Hon'ble High
Court order dated 13-3-97) does not submit its environment audit report as per the time
schedule prescribed in the scheme, the industry shall be liable for appropriate directions
which include direction of closure.
2.10. Accountability/liability of the auditors/industries:
a) Where the audit report is found to be incorrect or inaccurate in respect of material
particulars for an industry by the GPCB, which may be appointed by Hon'ble High
Court or by the GPCB that industry shall be liable to be subjected to appropriate
directions.
b) The auditor whose report is found to be incorrect or inaccurate of particular industry,
then that EAR shall be rejected and action against the auditor and industry will be
taken accordingly.
24. Environmental Audits
c) Complaints against the auditor will be reviewed and investigated by GPCB through
Environment Audit Committee and substantiated complaint may result in cancellation
of Certification/ Recognition of the auditor against whom the complaint lodged.
31. Environmental Audits
REFERENCES
[1] Gupta Gunjan, ‘Environmental audit practices in India’, Volume no.2, Issue no.12
[2] Bahri S. K., A Framework for Auditing for Sustainable Development, October 2003-June
2004
[3] Mahwar R. S., Verma N.K., Chakrabarti S. P., Biswas D. K., Environmental auditing
programme in India
[4] Gujarat Pollution Control Board, Environment Audit Scheme: At a glance, Paryavaran
Bhavan, Sector 10 A, Gandhinagar- 382010, Gujarat, 2015
[5] www.environmentalpollution.in
[6] www.cag.gov.in