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Ongoing Project Auditing Procedures
- Randomly select project for audit
- Auditing is carried out on an annual basis.
- Projects will be randomly selected from the preceding year’s:
- completed projects (those which have submitted a Verification Report), and
- projects with outstanding VRs (those which have not submitted their report by the date indicated in the Declaration and have not responded to any reminders).
- Number of selected projects (sample size) will be proportionally representative of the number of scenarios in the selection pool described in section 1.2 of this procedure.
- Request project documents for audit
- The Project Team representative (by default the person who submitted the Verification Report) will be contacted to either:
- Upload the project documents following the provided instructions; or
- Provide alternative relevant contact details for the Project Team.
- As a minimum CL:AIRE expect the following to be submitted for audit:
- Materials Management Plan;
- Desk Top Study / Site Investigation Reports (for both Donor and Receiver sites);
- Risk Assessment;
- Remediation Strategy / Design Statement (depending on whether Route A or Route B);
- Verification Plan;
- Tracking system;
- Mass balance calculations;
- Communication pack (liaison with Local Authority / Regulator etc.); and
- Verification Report (usually uploaded to the CL:AIRE website as part of CL:AIRE’s Verification Report procedures), or
- in the event that the project is still ongoing, an equivalent of “Interim Verification Report” (summarising the project’s most recent updates) will be required as part of the audit documentation.
- The Project Team will be asked to identify the documents they wish to be considered for audit on a DoW CoP Audit Request Document Reference Form.
- The Project Team representative (by default the person who submitted the Verification Report) will be contacted to either:
- Assess Documents
- Tier 1 - Document screening (~10% of the audit work).
- Checking all required documents have been submitted.
- Tier 2 – Industry guidance compliance review (~15% of audit work).
- Reviewing the supporting documentation against relevant industry guidance / standards (Land Contamination Risk Management (LCRM), July 2023; BS 10175:2011+A2:2017; and BS 5930:2015+A1 2020 etc.).
- Tier 3 - DoW CoP compliance review (~75% of the audit work).
- Assessing how well the project accords with DoW CoP requirements as set out in the DoW CoP Main Document, Version 2, March 2011 and the DoW CoP FAQs.
- Tier 1 - Document screening (~10% of the audit work).
- Audit Report
- The Audit Report documents the project audit.
- The individual lines of evidence and supporting documents / reports are each graded on how well they accord with the DoW CoP and relevant industry guidance. From this, an overall grade is assigned to the project.
- There are currently three grading categories (Good, Improvement Possible and Non-Conformant); the description for each is provided below in Table 1.
- Quality Assurance and Quality Control (QA / QC)
- A proportion of the projects selected for audit undergo a QA / QC review.
- There are two types of QA / QC review:
- Internal review:
- undertaken by a senior member of staff at CL:AIRE;
- notes and observations are available to the reviewer; and
- approximately 30% of the total number of audits completed are reviewed
- External review:
- undertaken by an experienced, independent reviewer;
- blind review - no notes or observations from the initial audit are available to the reviewer; and
- approximately 5-10% of the total number of audits completed are reviewed.
- Internal review:
- Discrepancy review.
- Any discrepancies between the original grading and the QA / QC grading(s) are discussed, and a final grade is agreed upon.
- Outcomes and Feedback
- For projects that are graded as ‘Good’ or ‘Improvement Possible’, no further action is taken.
- Projects that do not reply to audit requests and that are found to be ‘Non-Conformant’ may trigger the use of CL:AIRE’s Qualified Person or Project Team Disciplinary & Grievance Procedures.
- CL:AIRE does not provide specific feedback to Project Teams or QPs on the outcome of the audits.
- Generalised feedback will be provided in an annual Audit Report which will be made available to the industry.
- All audit outcomes are made available to the regulators on request.
Table 1 Current Grading System
Good |
|
Improvement Possible |
|
Non-Conformant |
|