Audit system

The site contamination audit system and the accreditation and use of site contamination auditors are key strategies in the management of site contamination in South Australia.

The legislative framework for the statutory audit system is established in the Environment Protection Act 1993 and the Environment Protection Regulations 2009. The audit system became fully operational on 1 July 2009.

The EPA is responsible for administering the audit system. The EPA maintains the integrity of the audit system by accrediting individuals as site contamination auditors and ensuring site contamination audits are carried out in accordance with the legislation and guidance issued or approved by the EPA.

Auditors are senior and experienced site contamination professionals who are accredited by the EPA. The accreditation process is rigorous and intentionally set at a very high level. Auditors independently examine and review the work carried out by site contamination consultants and provide their written opinions and determinations in the form of site contamination audit reports. Auditors must not have a conflict of interest or prepare false or misleading reports. The penalties for doing so can include imprisonment.

The EPA has prepared detailed guidance in the Guidelines for the site contamination audit system, to support the audit system and to assist auditors and others in understanding and complying with legislative requirements. It provides guidance on the audit system, the accreditation process for site contamination auditors, and the role and responsibilities and obligations of site contamination auditors and other persons in relation to the audit system. The current version was updated in August 2019.

A series of information sheets which provide an overview of the audit system, auditors, and site contamination audit reports and audit statements has also been published to assist people who may need to use the audit system. They are available for download:

Audit process | Auditor register | Audit system forms | Auditor accreditation

Audit process

An audit may be necessary for the following reasons:

to satisfy requirements under the Environment Protection Act 1993
to satisfy the requirements of planning and development processes under the Development Act 1993
other reasons, for example:

as required by EPA standards or guidelines
voluntary, such as due diligence.

Once it has been identified that an audit is required, the steps involved and duration of the audit process may vary depending on the point at which the audit is commissioned and the complexity of issues associated with the audit site which will determine the level of assessment and/or remediation to be carried out.

A site contamination audit (audit) is carried out by a site contamination auditor.

Auditors are expert individuals who are accredited by the EPA and are subject to specific legislative obligations and mandatory guideline requirements. A site contamination auditor is defined in section 3(1) of the Act as a person accredited under Division 4 of Part 10A of the Act. Only a natural person may be granted accreditation.

Auditors must comply with the relevant provisions of the Act, associated Regulations and relevant EPA guidelines. The legislation provides for significant penalties for offences and breaches of specific legislative requirements including expiations, fines and/or imprisonment. The Act requires auditors to ensure that in conducting audits they are not subject to a conflict of interest. The independence of auditors is a fundamental aspect of the audit system. The integrity of the audit system is based on auditors providing an independent and expert evaluation of the condition of a site.

The completion of an audit is the provision of a site contamination audit report and site contamination audit statement (the prescribed summary of the audit findings) by the auditor. The audit report provides the auditor’s determinations and audit outcomes.

The Act requires an audit report and related audit statement to be prepared and provided by the responsible auditor to the person who commissioned the audit, the local council and any other prescribed body, and the EPA on completion of the audit.

Prior to audit completion an auditor may be able to provide interim audit advice. Interim audit advice may be useful in supporting development applications and is required to be prepared to support waste derived fill proposals. Interim audit advice is not an audit report. An audit report is required in order to complete the audit.

Auditor register

This is a register of auditors currently accredited by the EPA.

Audit system forms

Notifications

Accreditation

Auditor accreditation

Auditors are expert individuals who are accredited by the EPA and are subject to specific legislative obligations and guideline requirements. Auditors are recognised in the field of site contamination as senior and highly knowledgeable and experienced site contamination professionals.

Auditor accreditation is granted to a person by the EPA^[1] under Part 10A of Division 4 of the Act. In fulfilling their role and responsibilities, auditors are expected to demonstrate a range of performance standards and professional behaviours including:

act in a professional manner and demonstrate a high level of independence, integrity and impartiality
consistently demonstrate a deep and broad knowledge and understanding of matters related to the field of site contamination
competently identify risks to human health and the environment
critically, logically and objectively discuss and evaluate factual and technical information related to the field of site contamination
use their knowledge and understanding perceptively and logically to describe and explain legislation and guidance relevant to the field of site contamination as well as the results and implications of human health and environmental risks related to site contamination
demonstrate a range of skills to coherently and effectively communicate information and demonstrate their knowledge and understanding
demonstrate leadership and constructive and effective collaborative and team building skills
demonstrate adherence to high ethical and professional standards which may be reasonably expected of senior environmental practitioners who are performing duties conferred upon them by the Act
advocate and implement risk assessment methods and approaches consistent with best practice for the assessment, remediation and management of site contamination.

The eligibility criteria and the application requirements for a person seeking auditor accreditation are prescribed in the Environment Protection Regulations 2009.

^[1]This decision of the Authority has been delegated to the EPA Chief Executive through the EPA Board delegations instrument.

The application and accreditation processes are described in detail in the EPA publication, Guidelines for the site contamination audit system.

How do I apply?

Applications for accreditation must:

be made to the Authority in the manner and form approved by the Authority; and
be signed by the applicant and completed in accordance with the instructions contained in the form
be accompanied by the prescribed fee.

Applicants should refer to the most recent version of the EPA publication, Guidelines for the site contamination audit system for an understanding of the accreditation process and the eligibility criteria for auditor accreditation.

When can I apply?

The EPA calls for applications from individuals who are interested in being accredited as site contamination auditors under Division 4 of Part 10A of the EP Act at least every 2 years. Information on current auditor accreditation periods is below.

Applicants must apply for accreditation during an open application period by completing and submitting the accreditation application form and application payment form which are available from the auditor forms.

There is currently no open auditor accreditation period.

Where can I obtain the application form?

Application forms are available from the EPA website during an open accreditation period.

What is the application fee?

The application fee is prescribed in Schedule 2 of the Environment Protection Regulations 2009.

How are applications assessed?

Written applications are checked by the Site Contamination Branch and provided to the Site Contamination Auditor Accreditation Committee for review.

Applicants who appear to meet the eligibility criteria will be invited to sit an open-book written examination and may then be invited to attend an interview with the accreditation committee.

A case study is used as the basis for the interview. Applicants selected for interview will be provided with the case study and a series of questions prior to commencement of the interview.

During the interview, the accreditation committee will test the applicant’s knowledge, understanding and ability to deal with issues associated with site contamination assessment, remediation and auditing.

Interviews typically last 1.5 to 2 hours (including pre-interview case study reading time).

Applicant’s will be assessed by the accreditation committee on their ability to:

demonstrate the knowledge, understanding and ability described in their written application and written exam
competently and objectively review data relating to the assessment
correctly identify the key risks posed to the environment and human health
communicate their knowledge and understanding effectively whilst demonstrating the logical basis of the decision-making processes used
carry out the role and responsibilities of an auditor.

What is the site contamination auditor accreditation committee?

The site contamination accreditation committee is a sub-committee of the EPA Board.

The accreditation committee comprises 5 members:

Chair of the Committee (EPA Director)
an expert in human toxicology from SA Health
a person experienced in auditor accreditation from another jurisdiction of Australia
up to two non-regulatory experts in the field of site contamination.

The purpose of the accreditation committee is to assess applications from persons seeking auditor accreditation and to provide advice to the EPA about whether or not the EPA should grant accreditation to a person and if not, the reasons why accreditation should not be granted.

Applicants selected for interview will be advised of the Board committee membership prior to interviews occurring to allow for any potential conflicts of interest to be identified.

Who decides if I am successful or unsuccessful?

The final determination on granting accreditation is made by the Chief Executive of the EPA.

Decisions relating to the grant of accreditation are made taking into account a range of information including:

the recommendations of the accreditation committee
relevant information where provided by other jurisdictions
the nature of the declarations made by an applicant in their written application
results of discussions with referees
results of a national police check.

How long will the application and accreditation process take?

It generally takes 6–8 months to complete the assessment of applicants and make decisions on the granting of accreditation for an accreditation period. Applicants will receive notifications throughout this period.

How much will I have to pay to become an auditor if successful?

The application fee is prescribed in Schedule 2 of the Environment Protection Regulations 2009. Payment of the application fee is required prior to accreditation being granted by the EPA.

If I am successful in being accredited, when will my accreditation commence?

If successful, the commencement of accreditation will be determined by the date the Chief Executive of the EPA approves accreditation.

How long will I be accredited for?

Accreditation terms are determined on an individual basis by the EPA, taking into account the individual’s qualifications and experience, and recommendations from the accreditation committee. An accreditation term cannot exceed 5 years as prescribed by the Regulations (regulation 59).

Are there penalties for providing false information in applications?

The legislation provides for significant penalties for offences and breaches of specific requirements of the audit provisions including expiations, fines and/or imprisonment.

Can I appeal any decisions?

Persons subject to decisions by the EPA in relation to accreditation are encouraged to contact the Manager, Site Contamination Branch to discuss any issues or concerns in the first instance. If matters remain unresolved, it may be raised with the Chief Executive of the EPA.

Appeal rights are also provided for by the Regulations (regulation 63).

Can I get a refund if I am not successful?

No. Application fees for accreditation are non-refundable.

Can I re-apply if I am not successful?

Yes. Applicants who are not successful will be given feedback from the EPA regarding their application.

Applicants are encouraged to review and consider this feedback if re-applying in future application programs.

Applicants are also encouraged to contact the Manager, Site Contamination to discuss any aspects of the feedback provided.

Will the EPA be holding an information session for prospective applicants?

The EPA holds information sessions on the application and accreditation process for prospective applicants during the written application stage of each accreditation period. Register your details with the EPA if you are interested in attending one of the information sessions.

I’m already an auditor in another state. How do I apply to be a site contamination auditor in South Australia?

Auditors accredited or appointed in an equivalent occupation in another State or Territory can apply for mutual recognition in South Australia.

Applications for mutual recognition can occur at any time using the mutual recognition form.

There is no application fee for mutual recognition applications.

Please contact the EPA if you require clarification as to whether your accreditation/appointment in another jurisdiction is recognised as an equivalent occupation in South Australia.

Further information

Please contact:
Manager, Site Contamination
Environment Protection Authority
GPO Box 2607
Adelaide SA 5001
Telephone: (08) 8204 2004
Fax: (08) 8124 4670
Free call (country): 1800 623 445
Email

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