If you’re going to take the time and effort to do something, you might as well do it correctly. It’s a simple philosophy that applies to a lot of things, but especially to safety auditing. A well-prepared and well-executed safety audit program can make a substantial difference in helping companies prevent accidents and injuries. In fact, most organizations with successful safety records have a well-organized safety audit program.
To be effective, it’s important that organizations understand — and adopt — the key characteristics of a successful audit program. Properly addressing these core areas can help ensure that program will deliver maximum impact with minimal risk, while continuing to add value over time.
Key #1 — Planning and preparation
A good safety audit program doesn’t come easily. The effort requires careful planning and diligent preparation. A good starting point is deciding why you want to do a safety audit. Or, more specifically, asking what is it you want to achieve? Answering this question gives your audit a focus and purpose. It also provides the foundation on which the audit program will be built.
Consider the following questions when planning for a safety audit program:
- What departments or operations are to be covered in the inspection tour?
- What items or activities are to be checked?
- How often are the inspections to be carried out?
- Who will conduct the tours?
- How will the inspections be conducted?
- What follow-up activity will ensure that corrections are, in fact, made?
- Does management understand that hazards or unsafe work practices need to be corrected and that this requires human resources, management and engineering expertise?
As with any well-functioning management system, an audit program must have guidelines and procedures that describe how the audit should be conducted and what corrective actions should be taken. These procedures should define audit activities, such as planning the audit, on-site activities and follow-up. Without written procedures, audits will be haphazard and inconsistent at best because they will be based on individual skills and preferences.
The audit protocol is an important tool that guides the auditor through the audit process. An effective protocol defines the steps that an auditor needs to take to audit a particular process or machine, and provides guidance on what to look for and where it’s located. Some companies use checklists or questionnaires as protocols, which provide a general framework for the areas and activities under review. It’s up to the auditor to probe deeper into these issues for a thorough evaluation of each area.
Involve key employees in the planning stages to ensure that every safety program, operation and hazard is addressed. This might involve discussions with the safety department, front-line employees and company managers to ensure areas they consider to be high priority are included. While it’s important to overlook nothing, be selective and make strategic decisions about which areas are to be reviewed. The goal is to audit things that have high impact and probability, such as electrical and explosive materials, machine guarding, and the use of personal protective equipment. This helps ensure that audits have the greatest return.
Key #2 — Defining the scope
A successful audit inspects the right things. Clearly, you can’t audit everything. Therefore, it’s important to prioritize the areas of focus. Too often, the audit team is constrained by how long the audit can last or the size of the audit team. This can result in insufficient time being available to dig deep enough to uncover less obvious issues, such as employee training and safety awareness.
Identifying key risk criteria can be helpful in evaluating individual subject areas and assessing their levels of scrutiny. These criteria include:
- Change — New or changed processes increase risk. This can include changes to materials, processes, facilities, equipment, people and even changes in leadership.
- Performance indicators — These imply that past performance is a predictor of future performance.
- Regulation — Evaluate the risks involved if the subject area is regulated by laws, standards or contractual requirements.
- Time — This considers how much time has elapsed since the subject was last audited.
Most audit programs give prominent attention to hazardous conditions that are easy to understand and simple to inspect. This includes lock-out/tag-out, confined spaces, fall protection and other areas that could cause injury. Too little attention is given to unsafe acts or hazardous employee behavior — even though accidents also can be caused by a bypassed or improperly designed safety system.
Audits typically don’t get to the root of deficiencies. Therefore, it’s important that the inspection program focus on basic items such as new-employee safety orientation, specific training for new jobs and supervisory follow-up. Likewise, because machine and process designers are familiar with many of the risks, they could play a major role in helping to design out hazards through proper selection of safeguards, controls and barriers best suited for the particular operation or process.
Another important question is whether a general inspection or targeted inspection is to be conducted. General inspections are considered comprehensive reviews of safety and industrial health exposures in a given area or complete factory. Targeted (or special) inspections deal with specific exposures in a given unit, section or even plant-wide. Such inspections might focus on electrical hazards in machinery or the hazards that might have generated back injuries as noted during a review of workers’ compensation reports.
A good audit program can include both inspection types. For example, one month, a program might involve a complete plant safety hazard tour; the next month, it could focus on personal protective equipment and how it’s used. In fact, OSHA encourages this mixed approach, believing that a combination of the two types of programs can strengthen a plant’s accident-prevention effort.
Key #3 — Involving the right people
The success of an audit relies heavily on the right personnel’s involvement. The size and type of business, number and expertise of employees, and special hazards and characteristics will dictate which staff members are assigned to the audit program. In many cases, a team approach is used, mixing facility and line managers, supervisors, engineers, operators and staff from other departments.
To determine the makeup of the audit team, consider:
- The type of safety audit to be conducted (general versus targeted)
- Employee experience and availability
- Time requirements and constraints
- Special hazards and operations
- Experience and cost of outside consultants
Safety program managers should review the audit team makeup critically to ensure a balance between objectivity and familiarity. Objectivity derives from using staff from other facilities or from other processes that aren’t included in the current audit.
In some cases, consider using an outside organization to conduct the audit. This brings to bear the consultant’s wealth of experience and a fresh set of eyes to view the situation. The biggest advantage to using a consultant is that it might be able to identify hazards the internal team failed to detect. A consultant also can provide industry-wide knowledge of procedures and practices that strengthen an existing safety program.
Either way, it’s important that the auditor have experience in auditing techniques, such as prioritization, sampling and following an audit trail. An auditor knowledgeable about a particular process or application can be especially effective. When choosing a consultant, consider its ability to supply products and address the device selection process. Also consider the development of new machine safeguarding specifications to help with certification and compliance demands.
Management must demonstrate complete commitment and support throughout an audit, particularly to ensure that action items generated are addressed adequately. This includes providing the required resources to implement the agreed-upon changes, including manpower and materials. The bottom line is that company leaders must not be afraid to uncover safety deficiencies or shortcomings. Management must be completely committed to doing a safety audit the right way and for the right reasons — not simply because it’s a mandate or makes managers look good.
Key #4 — Corrective action follow-through
Conducting the audit and reporting the findings is the easy part. The difficulty often begins with following up on the findings and implementing corrective actions. This is when improvement takes place, changes happen, root causes are eliminated, and controls and safeguards are put into place to prevent disasters. Audits can be planned thoroughly and conducted professionally, but unless deficiencies are corrected, the effort is pointless.
Typical failures that can occur at the audit follow-up stage include failure to understand the intent of the finding; failure to assign responsibility for follow-up of a finding; failure to track findings to completion; failure to document clearly what was done; and failure to allocate resources.
In many cases, plants correct the finding as reported, but fail to spend the extra time and effort to determine whether the deficiency represents a more endemic problem. Without understanding the root cause of the deficiency, the next audit will likely uncover the same problems.
When a plant conducts a safety audit, it must be prepared to remedy hazards that uncovered in the process. Safety managers should keep in mind that during an OSHA inspection, investigators have a right to access internal safety and health records, including records of safety audits. OSHA has the authority to issue citations and penalties for safety violations if you don’t act on negative findings.
Therefore, after installing safeguards, conduct follow-up assessments to verify that the potential risk has been reduced to an acceptable level. Closing the loop means that corrective action has been implemented, validated and verified. Likewise, periodic assessments of safety methods and practices confirm that specific programs are being followed and remain effective.
Key #5 — Training and education
Reducing potential risk also requires appropriate instruction about and training on safety procedures. Employees who might be exposed to machine or process hazards should participate in these training programs. The plant is responsible for implementing the training, but employees are ultimately responsible for applying the training and safety procedures to their work. Audit participants should have a fundamental understanding of the safety audit process. At a minimum, they should know:
- Objectives and mechanics of the safety audit process
- Two basic audit types (general and targeted)
- Benefits of safety audits
- Documentation requirements
- OSHA’s role
Expand training to include specific areas such as accident investigations, back injury protection, personal protection equipment, lock-out/tag-out and machine safeguarding. The safety director and facility manager are good candidates to develop and conduct training programs. Customize the training agenda and programs to meet the plant’s specific needs.
Effective safety audits are an important component of a successful safety program. To realize the audit program’s full benefits, it’s critical to have the right focus, involve the right people, allocate adequate resources, and follow-through on corrective actions. Plants with a well-planned and well-executed audit strategy forge a sustainable competitive advantage in the years to come.
Steve Dukich is senior application engineer and Mike Duta is manager of machine safety services at Rockwell Automation, Chelmsford, Mass. For more information, contact Tanja Bartulovic at [email protected] and (646) 440-4117.