I was once called to a meeting with a high management-level supervisor and I asked what I should do to be prepared for this meeting (I didn’t know what I was being called in for). His answer was no need to prepare but “Wear your square shoulders”.  Well, I wasn’t sure exactly what that meant so Google helped me:  to prepare to deal with something difficult in a determined way, or to show that you are prepared to do this. In the end, I wasn’t in trouble, exactly, but I was asked to do things differently and he knew I wasn’t going to like it. The rest of that story isn’t important, but the phrase has stuck with me.

I think preparing for a sanitary survey or any audit fits this phrase perfectly. Do something difficult in a determined way and show you are prepared to do this.

A sanitary survey is usually associated with a drinking water system and it is essentially an audit of everything you do in a water system. This type of audit is basically the same as a lab audit or inspection for a discharge permit. No matter what you call it, an audit can be scary and very stressful. There are things you can do to prepare yourself and your organization to help alleviate this stress, albeit not all of it!

First, every aspect of our work requires documentation. If you don’t write it down, it didn’t happen. You must do the documentation required every day, day in and day out! You can’t put this off. When you are preparing for an audit, you can check the documentation, know where it is kept and make sure any cross-outs are done correctly (ONE line, date and initials). If you find the documentation is not in order, make sure it is done correctly from that point on. You can’t go back and re-create documentation. You can write a memo to clarify that your entity made procedural changes to correct the issue, but that’s really about all you can do. When the auditor finds it – because let’s face it – they ALWAYS do! Then you explain, yes, we found that as well. Here is our corrective action memo (yes, write it down) and as you can see, from the date of this memo forward, we have been documenting this properly.

Second, clean and then clean some more. I’m talking white glove style, like your in-laws are coming to visit. I really believe auditors have a sixth sense. They can find things you never would have even considered. The thing is, if your plant, lab, etc. are clean then the perception is you have your act together. Now that doesn’t mean they won’t come across something you’ve let slip or have an observation of a different way to do things, but it leaves a good impression. Just like when the in-laws visit! An oil stain could lead them to ask about what kind of oil you use, which could lead to asking if it is NSF approved and if it isn’t, that could lead to a significant deficiency or violation. Clean.

Control the audit as much as possible. Set the schedule so you can have the appropriate people available for the auditor to talk to. Plan this out and make sure everyone knows they will be participating. I like to send an agenda with the appointment (or follow up to their appointment) along with specific meeting place maps. One time I didn’t do this and the auditor was waiting at the hand pump instead of the office. Not a big deal but wasted some time for sure. You know they will want to see just about everything in your system so plan the routes and time it will take to tour the sites.

Next, talk to your friends and neighbors. See what challenges they have faced during recent audits. There’s usually something auditors focus on every year. When a new rule is implemented, for instance, they will be making sure you have met the requirements of the rule. Speaking of your friends and neighbors – maybe ask someone to do a “pre-survey” of your system. This can really help point out things you may have been overlooking for years.

Prepare people or yourself to talk to auditors. I’m not suggesting you hide anything; however, you also don’t have to point out things you know you could do better. When an auditor asks a question, make sure you understand what they are asking then answer it concisely. This isn’t the time to tell stories or add extra information. If you don’t understand the question, ask the auditor to re-phrase it. If you don’t know the answer, do not pretend like you do. It is ok to not know the answer! You could say, "I don’t know, I would have to look at my SOP or ask my supervisor". Then the auditor can choose to ask for the SOP or ask your supervisor. That’s OK! Silence…prepare for the auditor to leave very awkward pauses and silence. Don’t try to fill in the silence. Politely wait for them to get to their next question. You can also move the tour along by asking if they would like to go to whatever the next stop is. It is uncomfortable to stand there and wait for them to ask the next question. It’s a tactic. I’m not suggesting that auditors are mean and nasty, but it is a trained tactic of auditing to get you to keep talking and tell them something which will lead them down another path.  

Also, make sure people are respectful to the auditors. Do NOT argue with them. If you disagree, you can ask them to show you the regulation they are referring to so you can understand their point of view. If at that point, you still disagree, you can discuss it after the report comes out and go from there. It is rarely to your benefit to argue with them. Say thank you. Yes, basic manners but you’d be surprised.

An audit should be approached as a learning experience. Improving what we do to protect public health is a good thing. I know we all take a lot of pride in our work, so it hurts when someone says we are doing it wrong. Learn from it and make corrections – “Wear you square shoulders”!

If anyone would like more information or help with an upcoming audit – let me know – I’d be happy to help!

Sherry Scaggiari is the Environmental Compliance Principal at the City of Aurora. Sherry has a chemistry degree from CSU and made her start in environmental contract labs over 30 years ago. She has worked for the city of Aurora for 14 years. She is responsible for compliance for Aurora Water including supervising the Quality Control Laboratory.