3. Audit Your Program and Facility Regularly

Conducting an Internal Mercury Audit Steps of a Mercury Audit

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• Obtain management approval, resources, and manpower.
  
  
• Communicate audit process and goals to employees. Establish a "no blame" policy and solicit employee input.
  
  
• Set up an audit team to collect, interpret, and communicate audit findings.
  
  
• Conduct the audit with facility processes in normal operation and during work hours so that questions can be asked of employees.
  
  
• Recommend waste reduction and pollution prevention steps in line with the audit findings.

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Phase 1: Understand the functions in your facility.

Phase one of the mercury audit involves going into the facility and developing a sound understanding of all the functional components and their interrelationships. It is worthwhile at this stage to solicit help from employees who are familiar with the day to day operations of the facility.

Step 1.: List unit functions.

Step 2.: Construct a function flow diagram

Step 3.: Construct a waste flow diagram.

Phase 2.: Inventory possible sources of mercury.

Phase two of the mercury audit encompasses identifying and managing sources of mercury to best minimize and eliminate mercury waste. A key component of this stage is to insure employees have a strong understanding of mercury management practices in the facility.

Step 4.: Inventory mercury content of raw materials. Keep a quantitative record of mercury. Know how much mercury is in use or stored on the premises, and how much has been spilled, recovered, or discarded.

Step 5.: Identify mercury-containing materials and equipment. Their arrival in the facility, the history of their use, and final destination.

Step 6.: Identify other in-facility sources of potential mercury contamination.

Phase 3.: Identify discharges and emissions from the facility that could become contaminated with mercury

Step 7.: Identify possible points of environmental release of mercury

Step 8.: Define best management practices to prevent release

Step 9.: Train employees to follow best management practices. Any reductions in use, spill incidents, or mercury recovered should be recorded.

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