Run a compliance program audit with five ordinary questions

Five ordinary questions, a stopwatch and a week. Find where your program leans on a scramble, a workaround or a single person's memory before an auditor does.
October 20, 2026
Compliance program audit thesis in green serif type: a scramble, a workaround, or a single person's memory.
In this article

Key takeaways

  • You can audit your own program with questions you already ask. Where is this assembly’s last test? Which facilities are overdue? What did we send this owner, and when?
  • Watch how the answer arrives as well as what it says. Wherever the answer involves a scramble, a workaround, or a single person’s memory, that’s where you’re exposed.
  • Time each answer and name who gave it. A slow answer and a single name tell you where to look first.
  • Fix the slowest answer first. Start with whichever question you could not answer without the one person who always knows.

If a property owner called this afternoon to say your notice never reached them, and asked when their assembly was last tested, how long until you had the answer in front of you? You know it lives somewhere. You’d open the spreadsheet, then the email folder, then the paper file, and then text a colleague who handled that route two years ago. That is a compliance program audit in one question.

You’d probably find it. The question is how, and whether anyone else on your team could have done the same thing without you.

That “how” is a free audit. It takes five ordinary questions and a stopwatch.

The test: how does the answer arrive?

Ask a plain question about your program and watch what happens next. If the answer comes from one screen, in under a minute, from whoever happens to be at their desk, that part of your program is in good shape.

Wherever the answer involves a scramble, a workaround, or a single person’s memory, that’s where you’re exposed.

Those three are different problems, so it helps to name them.

A scramble is when the answer exists but takes a hunt: three spreadsheets, an inbox search, a call to the tester. A workaround is when the system can’t hold the answer, so you built a side file, a color code, a note in a margin. And one person’s memory is when the answer is correct, but only because one coordinator remembers which landlord always needs a phone call.

Each one usually means someone is covering a gap in the process with their own time, and doing it well enough that no one noticed. That’s why they’re worth finding: the gap stays invisible until that person is out sick, on vacation or retired.

The five questions to run this week

Use real records. For the questions about one record, pick an assembly, site, industrial user or facility at random, ideally one you haven’t looked at recently. Then ask:

  1. Where is the last test, inspection or sample for this one? Open the actual record and read the result aloud.
  2. Which of our facilities are overdue right now? A list you could hand to someone today, not an estimate.
  3. What did we send this owner, and when? Every notice, every reminder, every follow-up, in order.
  4. Who else can answer these questions if you’re out Friday? Ask a colleague to answer question one for a record you pick, with you out of the room.
  5. What would an auditor ask for tomorrow, and how long would it take to pull it together? Imagine the request arriving by email at 4 p.m.

Swap in your own nouns: assembly for backflow, site for stormwater, industrial user for pretreatment, facility for FOG.

Question five does the most work, because it makes you invent the auditor’s questions yourself. Your own program’s records, your own permit or ordinance, and your own regulator’s last visit are a better guide than any generic list. Write down the first three things you’d expect to be asked for. Then try to produce them.

How to score what you find

For each question, write down two things: how long the honest answer took, and who gave it. Then flag any scramble, workaround or reliance on one person’s memory.

Grade how the answer was found. Say a correct answer took forty minutes and a phone call to a retired colleague, and a wrong one took ten seconds. The slow, correct answer is the bigger finding. The wrong one is a data error you can fix; the slow one is a process you can’t rely on.

Say you pick an assembly at an auto repair shop and ask question three. One row of your table might look like this:

Question and record Minutes to a confident answer Who answered, and could anyone else? Flag
3. What did we send this owner? (assembly at an auto repair shop) 20 You. No one else. Workaround, memory

In that row, the notices are in the system, but the call you made after the second notice is only in your notebook, and the owner’s new email address is in a thread only you have seen. It shows exactly where a second person would get stuck.

If you have a team, run it with them. Ask each person to answer one question without consulting the others. The differences between answers are as informative as the delays.

When two people give you two different last-test dates for the same assembly, you’ve found something an auditor would find too.

What the patterns usually mean

After a round or two, the findings start to cluster.

If question one is slow, your records are probably split across places, with results in one spot and inspection notes in another. If question two is slow, “overdue” may not be something your system calculates, so someone calculates it by hand every month.

If question three is slow, correspondence may be living in individual inboxes and mail merges instead of on the record. And if question four stalls, you have a succession problem that looks like a filing problem.

Question five pulls the others together. An auditor’s request is mostly questions one through three, asked in bulk and in writing, with a deadline.

The flags often sit in the handoffs rather than the hard parts of the work. A test result arrives and has to be entered. A site visit happens and has to become a record.

Wherever work crosses from one person, tool or format to another, check that spot first.

Fixing what you flag

Start with the question that took longest or depended most on one person. What would need to change for someone else to answer it in a minute?

Sometimes the fix is a process: a rule that every notice gets logged the day it goes out, or a shared list of the landlords who need a phone call, written down where the whole team can see it. Sometimes it’s a system question, because a spreadsheet can only calculate “overdue” if someone builds and maintains the formula.

Block one hour this week

Ask the five questions with real records, and write down the times and the names.

Then share the table with whoever backs you up, and let them see which answers depended on you.

If a system turns out to be part of the answer, three things in our software line up with the questions. SwiftComply’s backflow software includes a communications center where customer outreach is tracked in one location. The pretreatment software shows what is scheduled, pending, overdue or submitted. The stormwater software timestamps every record and action. Those match questions three, two and five, but the audit comes first, because it tells you which of them matters in your program.

Bring your findings to a demo and see how the software fits your program.

Talk to us about your compliance program