Audits

Scope

Audits may be voluntary, or they may be required. In a voluntary audit, your facility management decides on its own that it would be advantageous to conduct an audit, whether to evaluate compliance status, or to identify any suspected problems.

Regulatory citations

• 29 CFR 1910.119 — Process safety management of highly hazardous chemicals

Key definitions

• None

Summary of requirements

There are numerous benefits to an audit if it is properly conducted and acted upon. First, an audit can help to identify and correct regulatory problems, which can improve workplace safety, and help reduce company and personal liability.

A second benefit of an audit is that it can serve as an educational tool. It can increase employee awareness and understanding of environmental and safety regulations, and the audit process can also be an opportunity to demonstrate your company’s commitment to compliance.

Third, audits can potentially identify ways to improve the efficiency and cost-effectiveness of the compliance program.

Finally, workplace audits may be viewed favorably by regulatory agencies and criminal prosecutors. A thoroughly completed audit with proper follow-up can signal that your company is making a good-faith effort to comply with applicable regulatory requirements.

Although audits provide definite benefits, there are some potential negatives as well. Before conducting an audit, be aware of the following points.

1. An audit may uncover previously unknown problems, and the solution may not always be simple. If a violation of a regulation or law is discovered, what will be done? Should it be disclosed to the regulatory agency?
2. Failure to correct problems identified in an audit can potentially lead to many more problems. Implementing corrective actions in a timely manner is an important part of conducting an audit. If problems are identified in an audit and nothing is done to correct the situation, this information may be used against your company in future enforcement proceedings.
3. Consult with legal counsel to obtain further information about whether audit information must be disclosed to OSHA or EPA. OSHA and EPA do not, as a general rule, require disclosure of audit reports because these agencies do not want to discourage companies from self-auditing to improve environmental and/or safety compliance. However, there have been instances when the agencies have subpoenaed audit information during an investigation, using it against the company.

Some important points to keep in mind to help make safety audits a consistent benefit to your company include the following.

Research the areas to be inspected. The inspectors should know the jobsites that will be inspected, the types of tasks being conducted, and the accident experience of the work area(s). This will entail a little up-front research, but with those details, the auditor will have a better knowledge of the potential problem areas within the work area.

Gather the necessary equipment. Although it depends upon the area to be inspected, auditors should have the following items with them during the audit: personal protective equipment relevant to the area, any necessary sampling devices, camera, flashlight, any necessary electrical testing equipment, and paper and pen or pencil. The types of items brought into the area will depend upon how in-depth the inspection will be, the type of equipment that is being inspected, and the background of the inspector.

Ensure adequate training of the inspector. Unless the individuals to conduct the inspection have a well-rounded background in the safety field, they may need training or education on safety knowledge or regulations pertinent to the areas to be inspected. Reviewing the regulations will increase the inspectors’ knowledge base, and will probably enable them to observe more unsafe conditions or procedures.

Set an appropriate time for the inspection. Although spot audits of equipment and procedures are useful, it is helpful to arrange schedules where most of the equipment will be operating, and when most employees will be in the immediate area. On the other hand, the inspection should be performed at a time and in a way that it does not interfere with the production process. Unless the point of the inspection is to see if those time periods generate more hazards than other time periods, avoid particularly heavy workflow periods.

Use checklists effectively. Using a checklist during your audit will give you some indication of where you should begin to make your business safer and more healthful for all of your employees. But, remember that checklists are by no means all-inclusive, and you may wish to add to them, or delete portions that do not apply to your business. Carefully consider each item as you come to it, then make your own decision; don’t spend time with items that obviously have no application to your business.

After the audit, ensure that your recommendations and implementation of solutions are shared with all managers, line supervisors, and employees. Be sure that they understand what they are required to do, and the reasons for any changes in job procedures. Organize team meetings, or meet with each affected employee individually to explain any new information. The bottom line: always look for hazards that threaten the health and safety of your workers; then find the most efficient way to prioritize and control them.