The EFEC registration process has requirements for the company, the auditor and AHFA.  The figure below outlines the registration process.

This section describes the protocol that will be followed by the EFEC Board of Examiners (EFEC BOE) in registering facilities into the EFEC program.

The EFEC BOE will serve as the focal point of the EFEC program, providing administrative and authoritative oversight.  The principal duties of the EFEC BOE will include certifying EFEC auditors and providing final determination on EFEC registration.  The Board members will also be the stewards of EFEC, and have the responsibility of keeping the integrity of the program intact.  The EFEC Board of Examiners (EFEC BOE) is composed of seven (7) members, with a quorum of five (5).  Permanent members of the EFEC BOE include the Director of Environmental and Technical Services for the AHFA (Chairperson), Counsel to the AHFA on environmental matters (Secretary), and a representative from the EFEC Consulting Team.  The remaining four members shall be environmental professionals from AHFA manufacturing member companies.  These four industry representatives shall be appointed by the Chairperson and will serve nonconsecutive terms of two years.  

Facilities desiring registration must submit a letter of intent to AHFA upon the initiation of implementation.  Once a facility has implemented EFEC and undergone an audit by an EFEC certified auditor, the registration application must be submitted to the EFEC Board of Examiners by December 1 for review.  The registration application must include a copy of the facility’s EFEC manual and the auditor’s report. The EFEC auditor’s report must be signed by a certified EFEC auditor and a responsible company official.  

The EFEC BOE will review registration applications in December of each year.  A checklist (ATTACHMENT) will be completed by the EFEC BOE and kept on record.  The facility’s EFEC manual will be reviewed for completeness and the auditor’s report will provide detail and insight into the facility’s EFEC program.  The BOE will check the audit report to ensure that the audit included a document review, facility inspection, and interviews with employees at the facility.  The BOE must also ensure that the auditor was not involved in the implementation of EFEC at the facility. 

Once the EFEC BOE review of the required documents is complete, the EFEC BOE will vote on the registration of the facility.  The EFEC BOE may reach three possible conclusions:

If the EFEC BOE votes to grant EFEC registration to the facility, a registration letter will be sent to the facility and a certificate will be presented to a company representative at the AHFA Annual Environmental Conference.  EFEC registration is valid for a period three (3) years.  A formal presentation of EFEC registration will be given to a facility representative at the annual AHFA Environmental Conference. 

If the EFEC BOE is unable to reach a registration decision, a letter will be sent to the EFEC leader at the facility requesting more information.  A meeting with a representative from the facility and the auditor of the program may also be requested at the Board’s discretion.  The purpose of this meeting will be to clarify any questions the EFEC BOE may have or to obtain more information about the facility’s EFEC program so that a final registration determination can be reached. 

If the EFEC BOE denies registration, a letter detailing the reasons and a list of deficiencies will be sent to the facility.  The facility will have a period of thirty (30) days to provide proof that those deficiencies have been addressed and corrected.  Once the required documentation is received and reviewed by the EFEC BOE, the Board will vote on the registration status of the facility within sixty (60) days of receipt of a complete registration package.  

An annual EFEC maintenance audit is required to maintain EFEC registration.  The maintenance audit is not as detailed as an EFEC registration audit, and is designed to ensure that the EFEC program is implemented during the three-year registration period.  An executive summary of the EFEC maintenance audit, signed by a responsible company official and the EFEC certified auditor who conducted the maintenance audit, must be submitted to the EFEC BOE by December 1 of each year.  Failure to submit an EFEC maintenance audit summary will result in the issuance of a deficiency letter with a thirty (30) day cure period.  If the required documentation is not received within 30 days of the notice, the facility’s registration will be automatically revoked without any required BOE action.

Facilities seeking EFEC registration must have an audit completed by a certified EFEC auditor.  Certified EFEC auditors have the knowledge to plan, manage, and perform audits necessary for facility registration in the EFEC program.  The EFEC Board of Examiners (BOE) will certify auditors once per year or at the Board’s discretion.  Auditor certification is valid for a period of three years.  This section describes the process the BOE will follow to certify EFEC auditors. 

The EFEC auditor certification exam will be administered by the EFEC BOE annually.  Certified EFEC auditors must be environmental professionals with a combination of seven years of education and experience in the environmental field.  Prospective EFEC auditors must submit an application to the BOE by December 1 notifying the Board of his or her intent to become a certified auditor.  This letter of intent must include the person’s place of employment, job title, education and number of years experience in the environmental field.  

Training documents will be provided by the AHFA. It is the responsibility of the applicant to study the EFEC program and auditing process.  A mandatory EFEC auditor workshop will be given at the AHFA environmental conference or at the Board’s discretion, and the exam will be administered thereafter.  The exam consists of 50 multiple choice and/or true-false questions.  A score of 85% is considered passing.  The AHFA BOE representative will grade the exams.  The BOE will issue final certification to the applicants passing the exam.  EFEC auditor certification is valid for a period of three years.  At the end of this period, the auditor must attend the EFEC Auditor workshop and pass the exam.  The AHFA will maintain a list of certified auditors that have successfully completed EFEC training.