Ongoing Project Auditing Procedures
1. Randomly select project for audit
1.1. Auditing is carried out on an annual basis.
1.2. 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).
1.3. 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.
2. Request project documents for audit
2.1. The Project Team representative (by default the person who submitted the Verification Report) will be contacted to either:
2.1.1. upload the project documents following the provided instructions; or
2.1.2. provide alternative relevant contact details for the Project Team.
2.2. 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.
2.3. 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.
3. Assess Documents
3.1. Tier 1 - Document screening (~10% of the audit work).
3.1.1. Checking all required documents have been submitted.
3.2. Tier 2 – Industry guidance compliance review (~15% of audit work).
3.2.1. 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.).
3.3. Tier 3 - DoW CoP compliance review (~75% of the audit work).
3.3.1. 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.
4. Audit Report
4.1. The Audit Report documents the project audit.
4.2. 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.
4.3. There are currently three grading categories (Good, Improvement Possible and Non-Conformant); the description for each is provided below in Table 1.
Table 1 Current Grading System
|
Good |
● All documents present; ● Documents accord with guidance; and ● All DoW CoP requirements met and exceeded. |
|
Improvement Possible |
● All documents present; ● Documents generally accord with guidance; ● Minimum DoW CoP requirements met. |
|
Non-Conformant |
● Missing significant documents; ● Documents repeatedly do not accord with guidance; ● Minimum DoW CoP requirements not met; or ● Project falls outside of the scope of the DoW CoP. |
- Quality Assurance and Quality Control (QA / QC)
- 5.1. A proportion of the projects selected for audit undergo a QA / QC review.
5.2. There are two types of QA / QC review:
5.2.1. 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
5.2.2. 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.
5.3. Discrepancy review
5.3.1. Any discrepancies between the original grading and the QA / QC grading(s) are discussed, and a final grade is agreed upon.
- Outcomes and Feedback
6.1. For projects that are graded as ‘Good’ or ‘Improvement Possible’, no further action is taken.
6.2. 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.
6.3. CL:AIRE does not provide specific feedback to Project Teams or QPs on the outcome of the audits.
6.4. Generalised feedback will be provided in an annual Audit Report which will be made available to the industry.
6.5. All audit outcomes are made available to the regulators on request.