CHAPTER.

1
INTRODUCTION
The objective of this study is to investigate how different environmental auditing
techniques are being used in practice in different countries. The study also
examines how sustainable development is taken into account in various countries.
A framework of principles of best practice environmental auditing will be
developed based on academic literature and existing guidelines. This will be used
to compare guidelines on environmental auditing in both developed and
developing countries.
This objective will be achieved by three aims:
Develop a framework of environmental auditing for regularity perspectives
with the overall context/goal of sustainable development
Test developing and developed countries environmental auditing
guidelines against the framework to demonstrate how environmental
auditing can be used as a proxy for broader sustainability auditing; and
Recommend practical measures to raise performance of auditing in a
sustainable development context.
The research mainly focuses on environmental auditing by governments with the
aim
that this will benefit the Supreme Audit Institutions (SAIs) of developing countries,
which are mostly in the stage of introducing environmental auditing. More
specifically, this study will provide a basis for the development of guidelines for
environmental auditing in Bhutan which is in the process of developing the
environmental auditing guidelines/manuals in the SAI of Bhutan, although many
environmental laws, rules and regulations are already enforced.
This study explores how to move towards sustainability auditing by focusing on
establishing methods and tools by which progress can be measured. Furthermore,
the research is focused on studying the difference in the level of environmental
auditing standards between the SAIs of developed and developing countries.
The project was designed to achieve the objectives and aims discussed above. A
qualitative research approach developed by Bryan (2001) has been implemented.
Since there is a limited literature available on government environmental auditing,
standards and guidelines developed by International Organization of Supreme
Audit Institutions (INTOSAI) Working Groups on Environmental Auditing

(WGEA) and other groups were used. A checklist was used to look for the data and
mostly information downloaded from websites.

LITERATURE REVIEW
In this section the development of environmental auditing is discussed, followed
by the definitions developed in the environmental auditing literature. Good practice
environmental audit procedures and aims and objectives are explained. Next the
different levels of environmental auditing techniques and most importantly,
auditing for sustainability are also discussed. The relationships between
environmental auditing and sustainable development are then explored in the
context of government environmental auditing. The final section assesses how
improvements in environmental audits in a sustainability context could be
potentially measured with SAIs.

CHAPTER .2
WHAT IS ENVIRONMENTAL AUDIT?
Environmental auditing is not a particularly new discipline; however its popularity
as a means of assessing environmental performance has recently increased
dramatically (Welford, 2002). The first compliance audits can be traced back to the
United States. Corporations adopted this methodology during the early 1970s in
response to their domestic liability laws. The importance of environmental audits
has gained momentum greatly during the last few years, with the launch of EcoManagement and Audit Scheme (EMAS) in 1993 and the publication of ISO 14001
in 1996. More and more companies are finding it valuable to audit their
environmental impacts (Welford, 2002).
The United States Environmental Protection Agency (EPA) defined environmental
audit as a systematic, documented, periodic, and objective review by regulated
entities of facility operations and practices related to meeting environmental
requirements (EPA, 2003 cited in Anthony et al., 2003, p.36).
The term environmental audit was defined by Confederation of British Industry
as: the systematic examination of the interactions between any business operation
and its surroundings. This includes all emissions to air; land and water; legal
constraints; the effects on the neighbouring community; landscape and ecology;
the publics perception of the operating company in the local area.
Environmental audit does not stop all compliance with legislation. Nor is it a
green-washing public relations exercise. Rather it is a total strategic
approach to the organisations activities (CBI, 1990 cited in Paramasivan
2002, p. 149)
The most commonly used definition was given by the International Chamber of
Commerce (ICC, 1989 p.117), which defined environmental auditing:
as a management tool comprising a systematic, documented, periodic, and
objective evaluation of how well environmental organisation, management and
equipment are performing with the aim of helping to safeguard the environment
by: (i) facilitating management and control of environmental practices; and (ii)
assessing compliance with company policies, which include meeting regulatory
requirement.
Many authors have provided a number of definitions on environmental auditing.
Hayes et al., (1999) outlined the following features of environmental auditing:

 Audit is a systematic approach.

Audit is conducted objectively.
Auditor obtains and evaluates evidence.
Evidence obtained and evaluated by the auditor concerns assertions about
economic actions and events.
Auditor ascertains the degree of correspondence between assertions and
established criteria.
Goal, or objective, of the audit is communicating the results to interested
users.
Mc Donagh et al. (1997) defined environmental auditing as a process for checking,
on a regular basis, the environmental performance of an existing organisation or
activity. In the context of an environmental management system, Thompson (1995)
described environmental auditing as the regular, systematic review of the
environmental management system, compliance with laws and regulations,
conformance to policies, and the development of an action plan to deal with
deficiencies. Based on the ICC definition, Humphrey and Hadley (2000)
highlighted a number of features as follows:
Audits should be systematic and comprehensive.
Audits should be fully documented and where possible, substantiated with
physical evidence.
Audits should be periodic rather than one off procedure.
Audits should be objective, providing a true and fair view of the situation
at a site or within company.
Millichamp (1996) provided the same meaning as the definition of ICC.
However, he made some notes on this definition:
It is seen as a management tool but might also be used a tool of regulatory
agencies and any contact groups in assessing environmental performance.
It should be systematic, documented, periodic, and objective.
It is of performance.
The objective is to contribute to safeguarding the environment.
It is part of a management system.
It is concerned with assessing company policies connected with regulatory
requirements but also with appropriate standards as perceived by
management.

From comparing and analysing the definitions, it was found that they have the
following commonalities:
Systematic and comprehensive;
Documented;
Periodic;
Objective;
Independent; and
Evaluation.
According to Donald (2004), environmental auditing is a catch-all term used to
describe a range of audit activities focussed on the environment. SAIs are normally
carrying out three basic types of auditing with an environmental perspective:
financial (attest), compliance, and performance (value-for-money). At XV
INCOSAI in Cairo, INTOSAI adopted a framework definition of environmental
auditing. Basic principles underlying this definition are:
Environmental auditing is not significantly different from normal auditing as
practised by SAIs;
Environmental auditing may be included in financial, compliance, or
performance audits; and
The concept is based on government environmental auditing. The main focus of
this research is based on this definition.

Types and purpose of environmental auditing

There are numerous types and purpose of audits. Humphrey and Hadley (2000)
basically divided environmental auditing into three types of corporate audit:
* Compliance audits e.g. regulatory, EMS and internal standards;
* Single issue audits e.g. waste minimisation, transport; and
* Liability audits e.g. pre-acquisition, divestment and insurance.
Paramasivan (2002) categorised environmental auditing as cyclical auditing
programmes and single audits. He also divided objectives into three broad groups:
Compliance with regulatory codes, for example legal conformity;
Assistance in acquisition and disposal valuations, for example sale and

acquisition of facility; and

Corporate development towards green missions, for example monitoring of
corporate environmental policy and procedures
Welford (2002) discussed more detailed objectives of an environmental audit,
including:
1. Verifying compliance
Verifying compliance with standards or best available techniques.
2. Identifying problems
Detecting any leakage, spills or other such problems with the operations and
processes.
3. Formulating environmental policy
Formulating the organisations environmental policy if there is no existing policy.
4. Measuring environmental impact
Measuring the environmental impact of each and every process and operation on
the air, water, soil, worker health and safety and society at large.
5. Measuring performance
Measuring the environmental performance of an organisation against best
practices.
6. Confirming environmental management system effectiveness
Giving an indication of the effectiveness of the system and suggestions for
Improvement.
7. Providing a database
Providing a database for corrective action and future plans.
8. Developing the companys environmental strategy
Enabling management to develop its environmental strategy for moving towards a
greener corporate and performance culture.
9. Communication
Communicating its environmental performance to its stakeholders though reporting
will enhance the image of the company.

Five levels of environmental auditing techniques

Welford (2002) has suggested five levels of environmental auditing techniques

based on the central focus of the approach. This hierarchy proceeds from a static
base of compliance audits at the first level to a dynamic audit for sustainability at
the fifth level (Welford, 2002).
The different levels of audit
Environmental auditing techniques

techniques

are

shows

as

follows:

Source: Adapted from Welford 2002.

Level one
The most basic auditing approach is compliance auditing where performance is
measured as conformance with legislation, regulation and codes of conduct.
According to Welford (2002) until the early 1990s the majority of environmental
audits were usually little more than compliance audits.
Level two
Environmental Management Systems (EMS) emerged during the 1990s with
international standards such as ISO 14001 and EMAS. This has extended the
auditing process to systems audits where the focus is whether the EMS has been
effectively implemented. An EMS should be reviewed regularly in order to have
continuous improvement in environmental performance. The targets and objectives
at this level are largely self-determined (Welford 2002). This auditing is a crucial
component of an EMS.
Level three
This describes the traditional approach to environmental auditing which takes a
snapshot of the environmental performance of a company at one point in time,
usually on one particular site. The main focus is on the direct impact of an
organisation, site or process on water, land and the air, and therefore concentrates
on direct pollution effects, contingency planning and health and safety (Welford,
2002). In addition, it is important to note that for these three levels the mode of
assessment is essentially static, focusing on direct, easily measurable impacts and
conformity to the law and management system in place, all at one particular point
in time (Welford,2002)
Level four

At level four auditing goes beyond traditional environmental auditing techniques

which require a change in emphasis in a number of ways. The concept of
ecological auditing has three key features:
1. The mode of assessment must be dynamic;
2. There needs to be an increased emphasis put on life cycle impacts; and
3. A wider set of ecological issues need to be addressed (Welford, 2002).
A product life cycle should consider the impact of raw material procurement on
biodiversity, endangered habitats, human and animal rights and non-renewable
resources. Wheeler, 1993 argues these issues must not be ignored from an
ecological perspective although it may sound good especially to the agrochemical,
petrochemical, chemical and mining industries
Level five
Welford (2002) states that we need to widen the scope of auditing if our ultimate
aim is to move towards sustainability. This (level 5) is a holistic approach
predicated on a clear world view. There should be an understanding of the need for
further paradigm shift in business culture (Commoner 1990; Welford 1995;
Wheeler 1993 cited in Welford, 2002).
More specifically, waste minimisation, re-use and recycling should be driven by
the need to conserve the use of non-renewable resources. Sourcing of raw materials
should not have negative impacts on global biodiversity, endangered habitats or
human and animal rights. Overall corporate policies should examine the business
impact on both the developed and developing world, both now and into the future
(Welford, 2002).

The audit process

There are a number of different environmental auditing procedures advocated in

the auditing literature. A model of the audit procedure which is universally
accepted was first developed by Arthur D Little. This was later adopted by the
International Chamber of Commerce (ICC) in 1989. Based on this approach,
Humphrey and Hadley (2000) divided the environmental auditing process into
three main areas of activity:
Pre-audit;
On-site audit; and
Post-audit.
Each of these phases comprises a number of clearly defined objectives, with each
Objective to be achieved through specific actions. These actions produce results
in the form of outputs at the end of each phase.
Pre-audit activities
Once a commitment to auditing has been made a number of activities need to be
completed before the on-site activities commence. This is done to reduce the
amount of time spent in on-site activities which is expensive for both the auditee
and audit team.
The pre-audit activities usually include the following:
The sites that are to be audited need to be determined and selected.
The auditee should be informed of the date of the audit as soon as possible,
enabling them to adjust and become used to the concept.
The audit scope should be identified. The audit should usually be
consulted when establishing the scope.
The audit plan should be designed in such a way that it can accommodate
changes based on information gathered during the audit and effective use of
resources.
Audit team and assignment of responsibility should be established.
The chosen working papers should be collected. This will facilitate the
auditors investigations on the sites.
The background information on the facility including the facilitys
organisation, layout and processes, and the relevant regulations and
standards, should be collected.

 The background information on the sites historical uses, and the location of
soil and groundwater contamination should be collected.
The pre-audit questionnaire should be sent to auditee (Humphrey and
Hadley, (2000).
On-site audit activities
The on-site audit is the most important step of the audit procedure. This includes:
The opening meeting is the first step between the audit team and auditee. In
this meeting the purpose of audit, the procedure and the time schedule are
discussed.
Site inspection is the second step for on-site activity. In this step the audit
team may discover matters which are important to the audit but which are
not identified at the planning stage.
The on-site phase requires the audit team to develop a working
understanding of how the facility manages the activities that influence the
environment and how any EMS, if there is one, works.
Assessing strengths and weaknesses of the auditees management controls
and risks associated with their failure need to be established.
Gathering audit evidence involves collecting data and information using
audit protocol.
Communicating with the staff of the auditee to obtain most information.
Evaluating the audit evidence against the objectives established for the
audit and an agreed protocol.
An exit meeting takes place once all of audit findings have been finalised
with facility personnel (Humphrey and Hadley, 2000).

Post-audit activities
Post-audit activities begin with the preparation of a draft report. The draft report
should be reviewed by the facility personnel directly involved in the audit. The
final report should be derived from it and it should then be distributed to all
interested parties within the organization. Humphrey and Hadley (2000) confirm
that it is important for management to follow-up the report and develop an action
plan to implement those audit findings.
The ICC (1991) (cited in Humphrey and Hadley, 2000) identifies five elements of
a successful follow-up programme. These include:
* A standard action plan format;

* Established procedures for approving the action plan and communicating its
contents;
* Regular reporting of the action plans status;
* Special reporting and chasing up of overdue action; and
* Independent auditing of the action plan to verify that all actions sanctioned
have been completed.
The formal audit procedure is complete as soon as the action plan has been
completed.

Elements and principles

The ICC (1989) defines essential elements of an environmental audit that are
considered within the three formal stages of an audit. These include:
Management commitment;
Objectivity;
Professionalism;
Systematic procedures;
Written reports;
Quality assurance of the auditing system and audit findings; and
Follow-up and implementation (Metcalf, 2003).
An environmental audit is effective if it considers all aspects that are
essential for good environmental performance.
In interpreting this, Welford (2002) states some success factors for environmental
audit include:
(i) Top management commitment;
(ii) Staff involvement and participation;
(iii) Recognition of an integrated approach to environmental auditing;
(iv) Third party verification;
(v) Well-qualified audit team; and
(vi) Established audit frequency.
Barton et al. (1995) set out the main elements of environmental auditing including:
Review of Internal Practices (RIP)
Evaluation of the environmental impact of the agencys own operations and
practices.
Management Audit (MA)

Assess the effectiveness of the agencys organisation and procedures

in tackling environmental problems.
Policy Impact Assessment (PIA)
Evaluates an environmental impact of the agencys regulatory,
policy and service activities.
Statement of the Environmental report (SoE)
Statement covers authoritys environmental aims and commitment.
International Organisation of Supreme Audit Institutions (INTOSAI) and
Environmental Auditing
The INTOSAI is an international body for government auditors in member
countries of the United Nations. It was founded in 1953 in Havana and consists of
over 170 Supreme Audit Institutions (SAIs). The INTOSAI sets the standards and
guidelines for public sector auditing (INTOSAI WGEA, 2003).
SAIs play a major role in auditing government accounts and operations and in
promoting sound financial management and accountability in their governments.
INTOSAI supports its members in this task by providing opportunities to share
information, ideas and experiences in the field of government auditing among
legislative auditors of national governments (INTOSAI WGEA, 2003).
Every three years INTOSAI organises an International Congress for Supreme
Audit Institutions (INCOSAI), in which representatives of organisations such as
the United Nations and the World Bank also participate. The XVIII INTOSAI was
held in Budapest, Hungary in October 2004 and the next Congress will be hosted
by Mexico in 2007.
Within INTOSAI there are seven regional organisations of SAIs: South America
(OLACEFS), Central America and the Caribbean (CAROSAI), Europe
(EUROSAI),
Africa (AFROSAI), the Arabic countries (ARABOSAI), Asia (ASOSAI) and the
Pacific (SPASAI).The INTOSAI WGEA was established during the 14th INCOSAI
in Washington in 1992. The main aims of the Working Group are to assist SAIs in
acquiring a better
understanding of the specific issues involved in environmental auditing, to
facilitate exchange of information and experience among SAIs, and to publish
guidelines and other informative material for use by the SAIs. The WGEA is
currently the biggest21 INTOSAI Working Group. It started with 12 members, and
there are now 40 members from countries all over the world.

Environmental Auditing with Regularity Auditing Practices

The INTOSAI had issued Guidance on Conducting Audits of Activities with an
Environmental Perspective at XVII INCOSAI in Seoul, Republic of Korea in
October 2001. According to this guidance, environmental auditing encompasses all
types of audit: regularity (financial and compliance) and performance audits
(INTOSAI WGEA, 2003).
What is Regularity Auditing?
Regularity auditing is the periodic preparation of accounts and conduct of an audit.
It is one of the common elements of best practice based around eight key
principles of Social and Ethical Accounting, Auditing, and Reporting (Gonella et
al., 1998).
As an evolution of these processes, the International Auditing Practices Committee
(IPAC) defines environmental matters in a regularity audit as:
Initiatives to prevent, abate or remedy damage to the environment or to
deal with the conservation of renewable and non-renewable resources;
Consequences of violating environmental laws and regulations;
Consequences of environmental damage done to others or to natural
resources; and
Consequences of vicarious liability imposed by law (for example, liability
for damages caused by previous owners) (INTOSAI WGEA, 2003).
The International Federation of Accountants (IFAC) has issued an International
Auditing Practice Statement (IAPS) on environmental matters and relates
to guidance on various International Standards on Auditing (ISAs). The IAPS
concentrates on:
the consideration of relevant environmental laws and regulations;
obtaining and maintaining a sufficient knowledge of the business in
relation to relevant environmental matters;
risk assessments;
substantive procedures to detect any material misstatement of the financial
statements as result of environmental matters;
using the work of others;
management representations; and
reporting (Hayes et al., 1999).

Financial auditing approach to environmental issues

Governments are increasingly recognising that the costs arising from the
implementation of environmental policies and obligations may be significant.
These environmental costs, liabilities and impacts on asset values affect both the
preparation and audit of financial statements. The treatment of costs, assets and
liabilities in financial statements which would apply to the treatment of
environmental costs and liabilities are based on the established national and
international accounting standards (INTOSAI WGEA, 2003).

Compliance auditing approach to environmental issues

Compliance auditing with regard to environmental issues will make sure that
governmental activities are conducted in accordance with relevant environmental
laws, standards, and policies. This is applicable both at national and (where
relevant) international levels (INTOSAI WGEA, 2003).

Performance auditing approach to environmental issues

The INTOSAI Auditing Standards defined a performance audit as audit of the
economy, efficiency and effectiveness with which the audited entity uses its
resources in carrying out its responsibilities. The three Es are briefly explained
below:
* The economy is minimising the cost of resources used for an activity, having
the appropriate quality;
* The efficiency is the relationship between the outputs, in terms of goods,
services or other results and the resources used to produce them; and
* The effectiveness is the extent to which objectives are achieved and the
relationship between the intended impact and the actual impact of an activity.
Performance auditing is also referred to as Value for Money auditing.

Performance auditing of environmental activities may include the following:

Ensuring that indicators of environment-related performance (where
contained in public accountability reports) fairly reflect the performance

of the audited entity; and

Ensuring that environmental programs are conducted in an economical,
efficient and effective manner (INTOSAI Working Group on Guidance
on Conducting Audits of Activities with an Environmental Perspective,
2003 pp.124-127).
A performance auditing on environmental issues can be classified in the following
five types:
Auditing government monitoring of compliance with environmental laws
In most countries, an environmental department or other agency of the executive
government has responsibility for ensuring that environmental laws and regulations
are implemented and enforced. More specifically they are responsible for:
issuing permits that limit the quantity or concentration of pollutants
discharged;
monitoring the compliance with conditions stipulated in the permits
issued;
monitoring the quality of the environment to help identify other potential
breaches of laws and regulations;
helping in the interpretation of regulations, and providing other assistance
to regulated entities to assist in their compliance efforts; and
taking enforcement actions when violations occur (INTOSAI Guidance on
Conducting Audits of Activities with an Environmental Perspective,2003).
Auditing the performance of government environmental programmes
A government may also carry out a series of programs and activities to protect or
improve the environment. For example, in implementing those programs
Department of Agriculture help farmers to adopt new farming techniques with the
main aim of minimising pollution. Such environmental programs can be verified
from the government development plans and its annual reports.
In addition, it is the duty of the government auditor to identify the list of
international agreements on environmental matters to which government has
agreed. The auditors then examine the programs that have been implemented to
achieve them
(INTOSAI Working Group on Guidance on Conducting Audits of Activities with
an Environmental Perspective, 2003).

Auditing the environmental impacts of the other government programs

The impact of all government programs on the environment may not be good.
Some of its development programs may give rise to detrimental effects on the
environment in some way through their use of resources or their consequences for
the area in which they are implemented. For example, the primary objective of
infrastructure projects is to facilitate movement of people and goods on the
positive side. The building of roads, runways and railways have negative impacts
on the ecology of the area, the landscape and the air and the noise pollution
(INTOSAI Working Group on Guidance
on Conducting Audits of Activities with an Environmental Perspective, 2003).
Auditing environmental management systems
Various public organisations have environmental management systems and many
are introducing them. This helps to ensure that they are systematically setting
policies for continuous improvement in environmental performance and are
achieving the policy objectives and targets. This has been further strengthened with
the launch of accreditation schemes (e.g. ISO 14001 and EMAS) nationally and
internationally which enable organisations to obtain confirmation of the adequacy
of their environmental management systems and recognition that they are
operating such systems (INTOSAI Working Group on Guidance on Conducting
Audits of Activities with an Environmental Perspective, 2003).
Evaluating proposed policies and program on environment
Many countries do not grant a mandate for the government auditors to audit
policies. Their works are just confined to auditing the implementation of
government policies (INTOSAI WGEA, 2003). However, the government auditors
may be asked to give input on any proposed environmental policies or programs.
The results of the Third Survey on Environmental Auditing showed that one third
of the SAIs actively help government departments in one or more of the following
areas:
developing environmental indicators, performance measures,
Monitoring systems or other kinds of policy-information;
developing environmental management systems;
producing environmental reports; and
other types of assistance, for example SAI participated in workshops and
seminars, reviewed workshops organized by the environmental council of
the country and exchanged information (INTOSAI WGEA, 2000).

Authority of SAIs with regard to environmental auditing

The INTOSAI WGEA (2003) revealed that environmental audits are either
performance audits or a combination of a regularity and performance audits. The
types of environmental audits conducted by SAIs for three survey periods are as

Type of environmental audits

Source: INTOSAI WGEA on Fourth Survey, 2003
According to the survey report, during the last three years the most common issues
in environmental audits include-internal environmental management by public

authorities or departments (148 reports), fresh water (130 reports) and waste (116
reports). Other areas of concern are: agriculture, pesticides, local development and
forestry (56%), air pollution (45%), marine pollution (37%), problems related to
ecosystems (36%) and traffic (33%) (INTOSAI WGEA, 2003).
Mandate
In 2004, 94 per cent of SAIs had a legislative mandate to conduct environmental
audits and 82% per cent also had the mandate to carry out a performance audit.
Though the majority of SAIs carries out financial and performance audits, only 17
per cent of SAIs have a legislative mandate referring specifically to environmental
auditing (INTOSAI WGEA, 2003).
Range of bodies audited
Almost all SAIs are entitled to conduct the audit of environmental activities of
their national government. The third survey (2000) showed that 57 per cent of the
responding SAIs had taken up one or more audits with environmental issues. Many
SAIs can also audit activities of local, regional, provincial, or federal state
governments as well as state-owned enterprises. In addition, less than half the SAIs
are entitled to audit the activities of non-governmental public bodies (INTOSAI
WGEA, 2000).
Barriers to environmental auditing
According to the results of the INTOSAI WGEA (2003), 26 percent of the 114
SAIs did not experience any barriers to conducting environmental audits. The
previous surveys have identified the following barriers:
* Inadequate SAI mandates;
* Insufficient established environmental auditing norms and standards;
* Lack of skills or expertise within the SAI;
* Insufficient data on the state of the environment;
* Insufficient national monitoring and reporting systems; and
* Insufficient formulation of governmental environmental policy (Donald,
2004).

Environmental audit status

A theoretical approach for environmental auditing has been identified in a range of

literature, for instance those techniques such as compliance, systems,

environmental, ecological and sustainability audits (Welford, 2002). The
development and practice of environmental auditing varies between different
regions. The attention given to sustainable development issues is likely to vary
widely between SAIs (INTOSAI Working Group on Sustainable Development,
2003). The SAIs in developing countries are in the initial stages of introducing
environmental auditing,
for example the SAIs of Sri Lanka and South Africa reported to
INTOSAI that environmental auditing and reporting is still in their infancy
(Ananda, 2004; Louis, 2004). In this context, this project aims to ascertain to what
extent the theoretical techniques of auditing for sustainability are being followed in
SAIs of developing and developed countries. This will be done by developing a
framework to test current practice against best practice principles. Furthermore,
this will include an examination on the key challenges and/or problems faced at the
present juncture by the SAIs of developing countries and how they overcome them.

CHAPTER.3
METHODOLOGY

Introduction
The objective of this research is to assess and measure environmental auditing with
regularity and performance perspectives. This section discusses the various steps
used in the methodology for carrying out this research. In the first place it
discusses choosing the sample of SAIs from developing and developed countries
for this study. The reasons for focussing on those SAIs are explained. The
methodological approach such as desk-top study is also discussed. Finally, the
establishment of best practice framework and how this was used is
explained.

CHAPTER.4
CASE STUDY

In this section the status of environmental auditing in the four SAIs is discussed. It
also describes the documents of various SAIs examined for the study. It also
explains the evaluation of each SAI standard against the established best practice
framework.
Case 1: Sri Lanka
The Supreme Audit Institution (SAI) of Sri Lanka follows the Sri Lanka Auditing
Practice Standard (SLAPS 15), the Consideration of Environmental Matters in the
Audit of Financial Statements. The Statement does not establish any new basic
principles or essential procedures. Its purpose is to assist auditors, and the
development of good practice, by providing guidance on the application of the Sri
Lanka Auditing Standards (SLAuSs) in cases when environmental matters are
significant to the financial statements of the entity (Auditor Generals Department,
Sri Lanka).
The study showed that out of thirty three sub-criteria established in the framework
the standard has 9 Yes, 15 No and 9 Yes/No. This demonstrated that the Sri Lankan
standard met only few general principles include: systematic, objectivity,
documentation and independent that 54 per cent (Yes-27% plus Yes/No-27%)
issues were fully or partially referenced in the standard.
In contrast, the study demonstrated that the SAI had 15 No which comprised core
criteria such as quality assurance, effective training, human rights, and futurity.
showed that 46 per cent of issues were not at all referenced in the standard or
related documents.
Case 2: Indonesia
Environmental Auditing in Indonesia has been carried out as by the Principles and
General Guidelines regarding Implementation of Environmental Audits (Minister
of State for Environment, 1994). The principles and general guidelines are
intended to be used as guide for implementation of environmental audits for an
organisation or activity. The environmental audit is a voluntary action which can be
undertaken by the manager of an organisation or activity. This serves as an
instrument for managing and monitoring the environment (Minister of State for
Environment, 1994). The evaluation of these guidelines against the best practice
framework showed that the principles such as systematic, documentation,
objectivity, independent, and reporting are well referenced in the guidelines.
indicated that the Indonesian guidelines had 13 Yes, 13 No and 7 Yes/No out of 33
specific criteria. Demonstrated that the guidelines did not meet 40 per cent of the

criteria at all. Quality assurance, effective training, human rights and futurity were
amongst the criteria lacking in Indonesian guideline.
Case 3: The Netherlands
The Netherlands Court of Audit has developed a Code of Conduct for the
organization on 26 June 2000. The mission of The Netherlands Court of Audit is to
audit and improve the performance of the State and its associated bodies.
Objectivity, reliability and practicability are the principle characteristics of the
Court of Audits products. Besides there are other principles such as
professionalism, respect, openness, social responsibility, due care, independence
and objectiveness (The Netherlands Court of Audit, 2000).
The Netherlands Court of Audit was the Chair of INTOSAI WGEA. The
evaluation found that out of 33 best practice criteria the SAI of The Netherlands
met 27 criteria resulting in non conformance with 6 criteria only (Table 1.4). The
six issues which were not addressed include:
Existence of an explicit ethical framework;
Internal review;
Peer review;
External review;
Introductory training; and
Research into alternatives for non-renewable resources (Table 1.4).
It was also shown in Table 1.5 that the SAI had 82 percent of issues referenced in
the standard.
Case 4: Canada
The Canadian document A Sustainable Development Strategy for the Office of the
Auditor General-2003-2006 has been used in this study. The amendment of
Auditor General Act in 1995 established within the Office of the Auditor General
of Canada, the position of Commissioner of the Environment and Sustainable
development (Office of the Auditor General of Canada, 2004). The main business
of the office is to audit the governments activities on behalf of Parliament. After
the 1995 amendments to the Auditor General Act, the environment formally
joined the other three Es. In conducting an audit, the auditor asks questions such
as these:
Has money been spent with due regard to economy?
Has money been spent with due regard to efficiency?
Are procedures in place to measure and report on the effectiveness of programs?

 Has money been spent with due regard to the environmental effects of those
expenditures? (Office of the Auditor General of Canada, 2004).
Out of 33 sub-criteria established in the framework, the SAI of Canada satisfied
29.
The criteria which were not referenced in the standard/related document include:
* Existence of an explicit ethical framework;
* Peer review;
* Introductory training; and
* Research into alternatives for non-renewable .
The SAI of Canada is the present Chair of INTOSAI WGEA.

Comparison of actual audit practice against established criteria

The guidelines and principles of the four SAIs were compared against the eleven
main criteria. The result of the comparison is briefly described below:
Systematic :
The best practice criteria systematic was further divided into three sub-criteria
such as audit protocols, well defined methodology, and based on systematic plans
and procedures. The study showed that the two SAIs of developed countries
Canada and The Netherlands met these three criteria whereas the standards of Sri
Lanka and Indonesia referenced two criteria in full and one criterion partially .
Objectivity:
Objectivity has three specific issues such as true and fair view, impartial report,
and audit objective. The analysis revealed that the SAIs of Sri Lanka and Indonesia
referenced two criteria in their standards and partial referenced one criterion, the
impartial report. The Netherlands and Canada satisfied all three criteria.
Documentation:
Documentation is divided into three specific issues, fully documented, physical
evidence, and working papers. The finding demonstrated that the SAIs of
Indonesia, Canada and The Netherlands met all criteria whereas the Sri Lankan
standard did satisfy one criterion and two criteria partially, i.e. fully documented
and physical evidence (Table 1.4). Table 1.4 indicated that working papers were
well referenced in all the standards of four SAIs.
Independence

The best practice framework demonstrated that auditor and SAI independence was
an essential criteria. It was found that the Canadian and The Netherlands guidelines
satisfied all these criteria whereas the Sri Lankan and Indonesian standards
addressed two criteria and one issue partially (Table 1.4).
Transparency
Transparency is further broken down into three issues, freedom of access to
information, participation arrangement, and existence of an explicit ethical
framework. The study demonstrated that the SAIs of Sri Lanka and Indonesia
referenced one issue only. Similarly, two issues were referenced in the Canadian
and The Netherlands standards but did not meet the third criteria, existence of an
explicit ethical framework (Table 1.4).
Audit capacity
The environmental audit capacity of SAIs includes auditors competence, SAIs
competence, and specific personnel. Only two SAIs, Canada and The Netherlands,
had met all three criteria. The SAI of Sri Lanka did not meet two criteria and
partially satisfied one, specific personnel. The Indonesian standard had partially
met specific personnel and SAIs competence, but not auditors competence .
Reporting
The study demonstrated that three SAIs, Canada, The Netherlands and Indonesia,
have good reporting, satisfying all three criteria such as regular and timely,
concise, and documented evidence. Sri Lanka did not meet one of the three criteria,
concise, and met partially the third criterion; regular and timely (Table 1.4).
Quality assurance
Quality assurance is further divided into three sub criteria, internal review, peer
review and external review. The three SAIs, Sri Lanka, Indonesia and The
Netherlands had not addressed this in the standards. Canada satisfied two criteria,
internal review and external review .
Effective training
The study showed that introductory training was lacking in all SAIs guidelines.
The other two training issues-technical and continuing education were included in
the standards of Canada and The Netherlands. The Indonesian standard did not
meet anyof criteria whereas Sri Lankan standard met one criterion, continuing
education .
Human rights

Human rights are further divided into three sub-criteria such as health and safety
legislation, dissatisfaction, and fair wage policies. The study showed that the SAIs
of Canada and The Netherlands satisfied these three criteria. The Sri Lankan and
Indonesian standards did not meet two criteria, dissatisfaction and fair wage
policies.
Futurity
The study demonstrated that out of three sub-criteria under futurity principle the
SAIs of Sri Lanka and Indonesia did not meet any issues. The guidelines of Canada
and The Netherlands satisfied two criteria such as phase out of non-renewable; and
reduce, repair, reuse and recycling. None of the standards included one
criterionresearch into alternatives for non-renewable (Table 1.4).
Principles not included in Sri Lankan and Indonesian Guidelines
Out of thirty three issues discussed in the best practice framework, Sri Lanka
satisfied
eighteen criteria either fully or partially and not met fifteen criteria at all .
The issues not addressed by Sri Lankan standard include:
(i) Audit protocols;
(ii) Audit objective;
(iii) Participation arrangements;
(iv) Existence of an explicit ethical framework;
(v) Auditors competence;
(vi) SAIs competence;
(vii) Concise;
(viii) Internal review;
(ix) Peer review;
(x) External review;
(xi) Introductory training;
(xii) Technical training;
(xiii) Dissatisfaction;
(xiv) Fair wages; and
(xv) Research into alternatives for non-renewable resources (Table 1.4).
Similarly, the standard of Indonesia referenced twenty criteria either fully or
partially
and thirteen criteria not addressed at all
The criteria not referenced by Indonesian standard include:

(i) Audit objective;

(ii) Participation arrangements;
(iii) Existence of an explicit ethical framework;
(iv) Auditors competence;
(v) Internal review;
(vi) Peer review;
(vii) External review;
(viii) Introductory training;
(ix) Technical training;
(x) Continuing education;
(xi) Dissatisfaction;
(xii) Fair wage policies; and
(xiii) Research into alternatives for non-renewable resources (Table 1.4).
The analysis showed that out of 33 best practice criteria, Sri Lanka had not
satisfied 15 criteria and the Indonesian standard had not met 13 criteria (Table 1.4).
The result demonstrated that these two SAIs follow almost the same principles of
environmental auditing. This can be therefore concluded that two SAIs of
developing countries are still in the introductory stage of environmental auditing.
This finding is consistent with previous study by Ananda (2004).
Principles not included in The Netherlands and Canadian Guidelines
The Netherlands SAI has satisfied twenty seven criteria and not referenced six
criteria whereas the SAI of Canada met twenty nine criteria and four not referenced
The six criteria not referenced in the SAI of The Netherlands include:
(i) Existence of an explicit ethical framework;
(ii) Internal review;
(iii) Peer review;
(iv) External review;
(v) Introductory training; and
(vi) Research into alternatives for non-renewable resources (Table 1.4).
Similarly, the four issues not addressed by the Canadian standard include:
(i) Existence of an explicit ethical framework;
(ii) Peer review;
(iii) Introductory training; and
(iv) Research into alternatives for non-renewable resources (Table 1.4).
From the above finding it is apparent that the standards of SAIs of Canada and The
Netherlands do not address only a few principles (as shown above). Furthermore,
this can be substantiated that Canada and The Netherlands satisfied 88 per cent and

82 per cent of criteria respectively (Table 1.5). We can therefore say that the SAIs
of this two countries have well developed standards or principles in auditing.
Principles included in all SAIs Guidelines
The results of the study indicate that there are eight principles which are well
addressed in the SAIs standards. These include:
(i) Based on systematic plans and procedures;
(ii) True and fair view;
(iii) Working papers;
(iv) Auditors independence;
(v) SAIs independence;
(vi) Freedom of access to information;
(vii) Documented evidence; and
(viii) Health and Safety legislation (Table 1.4).
These are best practice principles of auditing. Of 33 criteria, 8 are followed in all
SAIs. The result demonstrated that the SAIs of developing and developed countries
have less principles in common practice. Lack of common principles between SAIs
is an indication that there is no uniform and international standard in practice.
Principles not included in all SAIs Guidelines
In contrast, the analysis showed that there are four principles which are not
followed in all four SAIs. These include:
(i) Existence of an explicit ethical framework;
(ii) Peer review;
(iii) Introductory training; and
(iv) Research into alternatives for non-renewable resources (Table 1.4).
The finding shows that some basic elements of environmental auditing such as
existence of an explicit ethical framework, and introductory training are currently
not included in SAIs standards.
The comparison of SAIs standards against the best practice framework raises
following significant issues:
1. Transparency is an important principle of environmental auditing but most
SAIs had not referenced it in the standards or documents (Table 1.4). Furthermore,
the finding showed that the SAIs of developing countries i.e. Sri Lanka and
Indonesia
had less transparency as compared to Canada and The Netherlands. Table 1.4
demonstrated that out of three sub-criteria under transparency the SAIs of
developing countries met one criterion, freedom of access to information whereas
the SAIs of developed countries Canada and The Netherlands, met two criteria,

freedom of access to information and participation arrangements. It is evident from

the finding that standards of various SAIs vary from one country to another.
2. The research evaluated the environmental audit capacity of SAIs which
included auditors competence, SAIs competence, and specific personnel. Only
two SAIs Canada and The Netherlands had met all three criteria. The two SAIs, Sri
Lanka and Indonesia had partial or no specific personnel dedicated to
environmental audits and had no either auditors or SAIs competence (Table 1.4).
The finding is supported by a previous study conducted by INTOSAI WGEA
(2003) that of the 74 SAIs evaluated only 56 per cent (40 SAIs) have specific
personnel dedicated to environmental auditing. Fourteen SAIs have less than one
per cent of their staff dedicated to environmental audits and most of others have
between one and seven per cent (INTOSAI WGEA, 2003). However, it should be
noted that even if a SAI did not have dedicated personnel, it is possible for them to
conduct an audit as demonstrated by the 44 per cent of SAIs who have experience
with environmental auditing (INTOSAI WGEA, 2003).
3. The study demonstrated that quality assurance is one of the challenges faced
by SAIs. In this research, internal review, peer review and external review were
used as criteria for checking assurance. Quality assurance is the process established
by an SAI to ensure that needed controls are in place, controls are being properly
implemented, and potential ways of strengthening or otherwise improving controls
are identified (Mazur et al., 2005).
The analysis revealed that three SAIs, Sri Lanka, Indonesia and The Netherlands
had not referenced this in the standards. Canada met two criteria, internal review
and external review (Table 1.4). This finding is in contradiction to the Guidelines
on Audit Quality of INTOSAI where Mazur et al. (2005) mentioned that quality
assurance is one of the four sections of guidelines and is applicable to all SAIs. The
peer review process which determines the extent to which a SAI meets
international standards is not referenced in the standards of four SAIs.
4. The analysis showed that introductory training was lacking in all guidelines
whereas the other two training issues-technical and continuing education were
included in the standards of Canada and The Netherlands (Table 1.4). The
Indonesian standard did not meet any of criteria whereas Sri Lankan standard met
one criterion, continuing education. In general, this finding is consistent with the
previous study on environmental auditing (INTOSAI WGEA, 2003). However, at
the same time the result is not consistent with the guidelines on audit quality that
require SAIs to provide effective training, including introductory training to help
new arrivals adapt to the SAI. Technical training should be conducted to equip
auditors with the skills to perform audit tasks. Managerial training should be given
to allow employees to acquire skills to direct the work of audit units, and

continuing education to ensure that auditors maintain and enhance their capabilities
(Mazur et al., 2005).
5. The best practice framework demonstrated that SAI independence was an
essential criterion. Against three sub-criteria established for the issue in the
framework it was found that all four SAIs guidelines satisfied all of them .This
finding is consistent with the initiatives taken by the Task Force to strengthen
SAI independence (Swedish National Audit Office, 2002). The Task Force was
established by the INTOSAI Governing Board at its meeting in 1998 in
Montevideo, Uruguay under the chair of Auditor General of Canada, to examine
the state of independence of member SAIs.
It should be noted that the Task Force has to examine the state of independence of
member SAIs and make recommendations on ways and means to bring about
improvement in a proactive and productive manner. While the independence of
SAIs was addressed, the analysis in this study found that auditors independence
has not been discussed. The SAI as an organisation may be independent but the
individual auditors independence may not be the same.
6. The study demonstrated that three SAIs, Canada, The Netherlands and
Indonesia, have good reporting whereas Sri Lanka did not meet one of the three
criteria (Table 1.4). In general, the finding showed that SAIs have good reporting.
However, when this finding is compared with WGEA survey report (2003) it
appears that the selected countries for this research are performing better than
some others as WGEA reported that only 69 SAIs have produced 518 audit reports
between 2000 and 2002 (INTOSAI WGEA, 2003).
To answer the question at what stages are the various SAIs in environmental
auditing, the standards of the four SAIs are compared against the eleven best
practice principles. The study shows that the SAIs have included principles in their
standards in varying quantity. For example, the SAIs of Sri Lanka and Indonesia
respectively met 9 and 13 criteria fully out of 33 specific criteria (Table 1.4) which
we can say this is low standard. This can be further substantiated by Table 1.5 that
Sri Lanka and Indonesia had met 27 per cent and 40 per cent of criteria
respectively. The criteria addressed by Sri Lankan and Indonesian standards are the
basic elements of environmental auditing. If we use Welfords (2002) five levels of
environmental auditing techniques, the SAIs of Sri Lanka and Indonesia have been
conducting either systems auditing or traditional environmental auditing.
The Canadian and The Netherlands standards addressed 29 and 27 principles out of
33 which we can say that they have a high standard of environmental auditing. The
study demonstrated that SAIs of Canada and The Netherlands do meet the
principles ofenvironmental auditing and some elements for sustainability auditing
such as Health and safety legislation, dissatisfaction, and fair wage policies
(Human rights), and phase out of non-renewable, and reduce, repair, reuse and

recycling (Futurity). This can be further supported by Table 1.5 that Canada and
The Netherlands had satisfied 88 per cent and 82 percent of criteria. Similarly, if
we use Welfords (2002) five stages of environmental auditing techniques these
SAIs occupy level 4, ecological audits. The ecological audit has recognition for the
need to live in harmony with nature. The finding was supported by a previous
study that Nitkin and Brooks (1998) mentioned that in Canada it has been
suggested that a number of companies have moved beyond environmental auditing
to sustainability auditing. The two SAIs of developing countries Sri Lanka and
Indonesia satisfied 9 and 13 criteria in full and 9 and 7 partially out of 33 criteria.
The SAIs of developed countries Canada and The Netherlands met 29 and 27 out
of 33 criteria representing 88 per cent and 82 per cent respectively (Table 1.5). If
we work out the average percentage of satisfying criteria between the SAIs of
developing and developed countries, the computation shows 57 per cent in
developing countries (full/partial) and 84 per cent in developed countries which is
a big gap. From this result we can conclude by saying that the SAIs of developing
countries are very much laggingbehind in comparing to the SAIs of developed
countries. The conclusion supported the findings of previous studies.
Gap analysis and further research recommendation
This analysis has some limitations. The study design was well defined but the topic
of environmental auditing and sustainable development is a broad area. I should
again emphasise that the conclusions are based on the review of four SAIs and that
the sample is not representative of the various INTOSAI regions. This is
significant because the situation of the SAIs in the various countries can vary
widely. More studies on the status and potential influences on sustainability
auditing are needed. This is because no single issue is the cause and there is no
magic bullet. Inorder to get better results, a quantitative research method may be
recommended. In this study a research technique like interview, questionnaire,
checklist, and site visits were not carried out due to time and resource constraints.
The future research may be recommended to examine the actual auditing practice
in different SAIs using audit report case studies.

CHAPTER.5

CONCLUSION AND RECOMMENDATION

The primary purpose of this study was to examine the environmental auditing
standards of SAIs of various countries. For this research a sample of four SAIs,
two from developing countries and two from developed countries, were identified.
The literature review showed that there are numerous principles to guide best
practice environmental auditing. Incorporating these principles eleven criteria with
three subcriteria each were included in a framework for evaluating the practices of
four selected SAIs. The eleven main criteria were:
(i) Systematic;
(ii) Objectivity;
(iii) Documented;
(iv) Independence;
(v) Transparency;
(vi) Competence and qualification of auditor;
(vii) Reporting;
(viii) Quality assurance;
(ix) Effective training;
(x) Human rights; and
(xi) Futurity.
The standards of SAIs were compared against established criteria to find out at
what level the particular SAIs stand. From the comparisons it was apparent that the
SAIs of Sri Lanka and Indonesia are in the infant stages because they satisfy only
the basic criteria of environmental auditing and not the elements for sustainability
auditing. If we use Welfords (2002) five level audit hierarchy based on the focus
of the approach at each level, the SAI of Sri Lanka falls in level 2. In systems audit
at the second level an environmental management plan is usually in place, and
audit appraises the systems within the organisation in addition to checks related to
level one. The targets and objectives at this level are largely self-determined. The
SAI of Indonesia is moving towards level three, traditional environmental audit,
which is a static economy-wise appraisal and which takes into account
interconnectivity of various sectors, protection of employees and the community,
and contingency planning. The study showed that SAIs of Canada and The
Netherlands do meet the principles of environmental auditing and many elements
for sustainability auditing (82% and 88% respectively in Table 1.5). Similarly, if
we use Welfords (2002) five level audit hierarchy the SAIs occupy stage 4 i.e.
ecological audits. The ecological audits recognise and assert the need to live in
harmony with nature. It is therefore evident from the findings of study that the
SAIs of developing countries are lagging behind in comparing to SAIs of

developed countries. However, considering the barriers to developing and

conducting environmental auditing discussed earlier in the literature review, the
following suggestions therefore may be recommended:
1. Effective training
SAIs staff should undertake appropriate and professional competence and timely
effective training. The training may include introductory training, technical
training, managerial training, and continuing education. The analysis revealed that
training is lacking in the SAIs. Table 1.4 illustrated that SAI of Sri Lanka do meet
one of three training criteria established in best practice framework, continuing
education whereas the Indonesian standard does not satisfy any criteria.
Furthermore, the SAIs of Canada and The Netherlands meet two out of three
criteria. The finding is further strengthened by the finding that 83 per cent of SAIs
have lack of skills or expertise within the SAI (INTOSAI WGEA, 2003).
In view of this, all types of training should be imparted to employees of SAIs so
that their skills or expertise are enhanced. The study also showed that the
introductory training has not been addressed in all SAIs standards and therefore
this may be recommended. This training is useful for the new arrivals to adapt to
the SAI. Every SAI can conduct this training through in-house training by their
internal staff/employee.
2. Transparency
The analysis showed that transparency is lacking in SAIs. Transparency can be
enhanced through freedom of access to information, participation arrangements,
andexistence of an explicit ethical framework. Transparency must be both internal
and towards individuals and organisations the SAIs deal with. It should be made
clear that the SAIs are open to criticism. Transparency with the outside world must
display the standards that SAIs use and the results they achieve.
3. Quality assurance
From the findings it was seen that the quality assurance is a pertinent standard. It is
an assessment process focussing on the operation of the quality control system. In
order to have good auditing, a SAI should have four main types of quality
assurance include internal review, external review, peer review and feedback from
audits (Mazur et al., 2005).
An internal review is establishing a separate office, independent from the audit
units,reporting directly to either the president in an audit office or the relevant
collegiums in a court of audit (Mazur et al., 2005). In external review, a private
audit firm might be asked to review a sample of attestation audits. A consulting

firm or academic experts could be asked to review selected performance audits

(Mazur et al., 2005).
Peer review assesses the extent to which a SAI meets international standards. Such
a review generally involves experienced auditors from other SAIs (Mazur et al.,
2005).
4. Audit capacity
It is important that there should be an audit capacity such as auditors competence,
SAIs competence and specific personnel dedicated to environmental auditing. The
analysis showed that the SAIs of developed countries have audit capacity whereas
the SAIs of developing countries have less or no capacity. Table 1.4 demonstrated
that out of three sub criteria established in the framework, the developing
countries SAIs Sri Lanka and Indonesia, do not satisfy all criteria whereas Canada
and The Netherlands meet all criteria.
The auditors and SAIscompetence can be improved through employment of
qualified staff. Furthermore, auditors competence can also be enhanced through
conduct of trainings, conferences, seminars and meetings from time to time. The
most important is that there should be qualified specific personnel allocated in
SAIs who looks after the environmental auditing. The audit capacity can also be
improved if the SAIs of developed countries share their experience, expertise and
ideas to SAIs of developing countries. There is no doubt that as time progresses
environmental audits will be undertaken inall SAIs especially as the public
becomes more and more aware of the need to protect the environment.

6.REFERENCES
Ananda, E. A. G. (2004). Getting Started: Beginning an Environmental Auditing
Initiative in Sri Lanka, International Journal of Government Auditing, Vol. 32,
No.2, pp. 28-29.
Australian National Audit Office (2005) Sustainability Reporting-The Role of
Auditors.http://www.anao.gov.au/WebSite.nsf/0/13A1FBB95D56FE7FCA256
FB000E6D46 16.05.2005.
Awasthi, A. K. (1999) Environmental Issues in Audit, India.
Auditor Generals Department (undated), Sri Lanka Auditing Practice Standard
(SLAPS 15) The Consideration of Environmental Matters in the Audit of
Financial Statements.
Anthony, R.T. Emery and Michael, W (2003) Eco-Auditing and Environmental
Liability: an International Perspective. Managerial Auditing Journal 18/8
(2003), pp. 631-636.
Bryman, A. (2001), Social Research Methods, Oxford University Press Inc., New
York.
Barton, H. and Bruder, N. (1995) A guide to Local Environmental Auditing,
Earthscan
Publications Limited, London.
Commoner, B. (1990) Can capitalists be Environmentalist? Business and Society
Review, 75, pp. 31-35.
Donald, R. Drach (2004) International Organisation of Supreme Audit Institution,
International Journal of Government Auditing, April 2004, Vol. 32, No. 2, pp.
01-44.
Department of the Environment (1990) This Common Inheritance: Britains
Environmental Strategy HMSO, London.
Department of the Environment (1994) Sustainable Development: The UK
Strategy
HMSO, London.

LIST OF CONTENTS
1. INTRODUCTION
2. ENVIRONMENTAL AUDITING

3. METHODOLOGY

4. CASE STUDY

5.CONCLUSION

6.REFERENCE

ENVIRONMENTAL AUDITING