Re-centering a mature program on operational reality
A national railway and freight operator manages environmental obligations across a large network, diverse facilities and a complex regulatory landscape. Compliance is inseparable from safe, reliable operations, so leadership treated the Environmental Compliance Audit Program as a core operating discipline, not a periodic exercise.
The audit program had been in place for years. It produced thorough site-level reviews and consistent activity, but leaders wanted clearer evidence that effort translated into risk reduction. They also wanted the audit process to better reflect how the business runs, especially where interfaces between operations and regulatory requirements create the most exposure.
Onterris partnered with the internal team to evaluate the program against three expectations: reduce compliance risk over time, support the operating business alongside regulatory obligations, and reinforce a culture of environmental and compliance excellence.
Turning audit activity into performance signal
The evaluation combined stakeholder surveys with a detailed analysis of audit findings. Onterris also compared audit results against agency Notices of Violation (NOVs) to assess year-over-year trends and pinpoint where audit activity aligned with external enforcement signals.
The assessment showed the program had become a legacy process repeated year after year with limited re-calibration to evolving risk. Some facility audits included up to 700 questions. That volume created burden for site teams and diluted focus on the conditions most likely to drive noncompliance or operational risk.
While the program was thorough, it did not consistently distinguish between isolated findings and systemic weakness. It also did not adequately evaluate the strength of the underlying compliance management system.
Shifting audits from checklists to controls
The redesign focused on making audits more targeted, more consistent and more aligned with business priorities.
Onterris worked alongside the client team to streamline audit protocols around the highest-risk regulatory requirements and operational interfaces. The team also shifted from checklist-based auditing to controls-based auditing, evaluating whether management systems and controls were effective in sustaining compliance.
Clear audit and compliance procedures standardized how audits are performed, scored and interpreted. The updated approach reduced audit fatigue while improving the ability to identify systemic issues that could lead to repeat violations or operational disruption.
Building ownership so the program sticks
Audit programs only change outcomes when the people responsible for compliance adopt the approach. Onterris engaged teams subject to audits and accountable for compliance through workshops and coaching that supported a shift from individual regulatory requirements to broader compliance management principles.
To reinforce adoption, Onterris augmented the internal audit leader role with an Onterris professional during implementation. That hands-on support strengthened consistency during rollout and helped build internal champions who could carry the program forward.
Results that held over time
Over the two-year period following implementation, the organization experienced a 35% reduction in agency intervention. The redesigned audit program improved visibility into compliance risks, strengthened accountability and better aligned environmental compliance with the needs of the operating business.
The updated structure positioned the organization to continuously refine its approach as regulations, operations and risk profiles evolve. For asset-intensive operators with mature but static audit programs, this work illustrates the value of stepping back to measure effectiveness, align audits to risk and invest in the ownership that sustains performance.
