Prevention, control, sustainability: plan and conduct effective safety audits.

Planning and conducting environmental, health, and safety (EHS) audits for a company or client's full range of operations can be a daunting undertaking. These operations may include both domestic and international manufacturing plants, research and development labs, fleet terminals and distribution centers, corporate aviation activities, and office complexes.

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The planning strategy must incorporate a variety of considerations, including whether to formulate the process on compliance or system-based issues. Other factors include emerging legislation, costs and availability of appropriate resources, identification of customers, frequency of audits, and confidentiality.

The definition of an audit varies from one organization to another. To start with, an audit is referred to by a number of different terms. They include appraisal, survey, assessment, evaluation, and inspection. Whatever you call it, when conducted properly, it is a systematic and comprehensive evaluation of a company's compliance programs--not just the current status, but over a period of time such as the past two or three years. It can be accomplished just as effectively by either internal (company) or external (consultant) auditors. When the new American National Standards Institute (ANSI) Z10 standard became effective last year, it contained the following definition of an audit: A systematic process for obtaining information and data and evaluating it objectively to determine the extent to which defined criteria are fulfilled.

Simply stated, a compliance-based audit is driven by a specific government agency (such as the U.S. Department of Transportation or the Environmental Protection Agency), company policies, facility-written requirements, or local facility standard operating procedures (SOPs), in that order. Typically, the most stringent of these takes precedence.

A system-based audit is more non-regulatory but necessary for a successful EHS program. This type of audit should include evaluating senior management's support and active participation (policy statement, staff meeting agenda item), employee participation (safety committees, "off-the-job" safety efforts, and so on), inspections and audits, training, contractor management, and emergency response programs. Some of these topical areas have regulatory implications, but collectively they are generally considered system-based programs. The usual suspects in this type of audit are ISO 14001, OSHAS 18001 and the Occupational Safety and Health Administration (OSHA) Voluntary Protection Program (VPP). With the advent of the ANSI Z10 standard, there is now another option available to companies.

Determining whether the audit program should be compliance-based or system-based is typically a result of a company's philosophy and the maturity of the program. Costs and frequency of an audit are usually driven by a company's concern for being viewed as a good corporate citizen by its stakeholders and the public.

Audits can be emotional exercises in some businesses. Those of us who have been on the receiving end know this. To be successful, the audit should address positive programs and activities (best practices), as well as program gaps, recommendations, findings, and local attention items. Another cornerstone for success is for the final report to be a clear and accurate evaluation of the overall EHS program and having the results sent to the right people in the organization, including senior management.

The EHS added value audit process

The EHS added value audit process has been designed to support increased performance and results with unique financial benefits over the traditional audit. The added value process has three primary tenets: recognition of all customers; knowledge transfer before, during, and after the audit; and consistency and quality throughout the process.

Identifying your customers who should be involved in the EHS audit process and receipt of the final report is the first step of the process. Typically, candidates include all domestic and international facility managers, risk managers, EHS professionals of the facility being audited, business unit managers, and company senior managers. All of these levels of management have a stake in the audit, and as such, the audit should be designed and conducted to fulfill each of their expectations.

For confidentiality purposes, most EHS audits are done under attorney-client privilege and anyone on the distribution list must have a need to see the report. This can complicate the customer list and the exchange of information. Consequently, the distribution list for the final report should be large enough to include all the stakeholders but small enough to protect the privilege.

Knowledge transfer includes an understanding of the responsibility to facilitate various activities as part of the team's audit duties including analyzing loss leaders for trends prior to conducting the audit, sharing and harvesting best practices during and after the audit, and using the guest auditor program as both a mentoring tool for team members during the audit and a means of distributing best practices between facilities.

Consistency and quality are critical if your audit program is committed to delivering a high quality product consistently to those involved in the process. The best opportunity to accomplish this on a regular basis is through the use of Web-based technology systems, including Aon Safetylogic.

The EHS added value audit process is divided into three phases that take place over several weeks. Phases include the pre-audit, the on-site, and the post-audit phases. Each phase is distinct in its activities, and each subsequent phase can be viewed as a progression. Collectively, they make up the entire audit process and depend on each other in order for the audit to be successful (Figure 1).

Essential pre-audit activities include developing a schedule, notifying the selected facilities, selecting teams for each audit, and coordination with the sites prior to the audit. The use of a pre-audit questionnaire is a very valuable method of communicating with the facility to be audited before the audit and sharing the results with the team. Some of these activities are typically completed in the preceding year in order to allow both the facility and the team members to schedule the time necessary to conduct the audit. When all of the information has been received from the various sources, the team leader or lead auditor should conduct a team meeting to review everything from travel arrangements to specific team assignments. When the team is comfortable with their preparations, all of the final arrangements should be communicated with the facility to avoid any misunderstandings.

On-site activities during the audit include: audit opening conference, an orientation tour, applicable program reviews (a two-step methodology), employee interviews, record reviews, daily debriefings, recommendations development (or findings), a pre-closing conference with EHS personnel, and the closing conference with the full staff to review the draft report.

Post-audit activities are generally focused on finalizing the draft report, assisting the site in either developing the corrective action plan or approving it when submitted, and tracking all findings through to completion. Some form of verification of the closure activities is recommended.

The opening conference is scheduled in advance and is held as early as possible on the first day of the audit. This is to advise the facility of the function of the corporate EHS department in general and the EHS audit process in particular.

The team leader is generally responsible for conducting the team portion of the opening. The site managing director or a designated representative usually presents an overview of the site, processes, or services provided; EHS goals and objectives; changes since the last audit; significant environmental impacts; risk management programs; loss experience; any pending or outstanding regulatory issues; safety performance data; and status of any remaining open action items from prior audits. The purpose and contents of the opening conference should be clearly communicated to the facility by the team leader during these proceedings.

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It is strongly recommended that the audit team participates in an orientation tour with facility representatives prior to the program reviews. The primary purpose is to observe facility infrastructure, briefly observe personnel performing their jobs, and identify areas that may require more in-depth review. It is always helpful to have a facility diagram and a means of recording observations during the tour. After the tour the team leader coordinates with the team and the appropriate facility staff to review the proposed audit agenda and finalize the interview and documentation review schedules.

Facilities are required to comply with all applicable national, state, and local laws and regulations; company EHS policy and EHS guidelines; divisional policies; and locally developed operating procedures. In order to verify that the facility has evaluated the EHS risks associated with its operations and is in compliance, the EHS audit process uses a two-step approach. This is designed to review program content and implementation. The audit team will determine whether the facility has developed the appropriate written programs, policies, or procedures to address EHS risks and impacts. The team will also decide whether the programs are effectively implemented.