Element 16: Internal EMS Audit To establish and maintain an internal audit program to periodically analyze the Biosolids EMS and determine whether it is effectively meeting its biosolids management policy, program requirements and biosolids program goals and objectives. The internal EMS audit program must define the scope, frequency, and methodology of the audits, assign responsibility for conducting the audits and communicating their findings, and designate individuals to whom these findings are to be conveyed. The internal audit must also evaluate the Encina Wastewater Authority’s (EWA) performance relative to established biosolids program goals, objectives and performance measures. The internal EMS audit program must cover all the EWA’s biosolids management program activities including those performed by a contractor. The internal EMS audit results must be reported to the EWA’s management in a way that they can take action to make necessary modifications to the EMS and biosolids management program. The EMS Coordinator must develop, or delegate the development of a comprehensive corrective action plan addressing each non-conformance identified by the internal audit. At a minimum, the EWA must maintain the following documents and records, as applicable, relating to the EWA’s audit program: Description of audit methodology, protocol, scope, and schedule; Identification of lead auditor(s), qualifications, and description of roles and responsibilities of auditor(s), management representatives, and others that may participate in, review, or be expected to act upon that audit; and Corrective and/or preventive action plans prepared resulting from an audit, and any related changes made to policies, plans, procedures, and work practices that occur as a result of an audit’s findings, evaluation, or follow-up actions. ELEMENT 16 DOCUMENT: Objective Definitions Summary Procedures Documentation Responsibility