Audit Teams

Aud/f/ng the operation of a system may be done by an external audit team composed of qualified people from within or outside the operating company. However, involvement... 

Consider the environmental benefits and the savings in process and waste-treatment operating costs, along with the payback period for an investment, to decide which options are viable candidates. Once this is done, the audit team can develop draft recommendations to include in the final report and presentation to top management. 

The Site I subeontraetor also laeked a baekup safety and health supervisor fully trained in site safety and health management. The aeting health and safety speeialist (HSS) at Site E was a site worker who had held the position for one week. This individual stated to the audit team that he did not meet the eorporate or SSAHP qualiheations required to hold that position. Apparently, while the Site E eontraetor was waiting for the results of the LTEV performanee test and the unit was not in operation, site management determined that less health and safety oversight was needed. 

The audit team found that at Sites B and H, safety and health personnel had suflfieient authority in most eases to thoroughly implement the safety and health plans. To faeilitate safety and health eom-plianee, anyone who entered Site H, ineluding delivery personnel, was required to view a brief video that summarized the site history and remediation operations, identified the hazardous substanees monitored on site, and deseribed site evaeuation proeedures. Site B s SSAHP did not mention speeifie subeontraetors and their roles and responsibilities however, it did indieate that the prime eontraetor had oversight responsibility for all safety and health aetivities and the authority to diseontinue or modify site operations when unsafe eonditions were deteeted. 

The OSHA audit teams found program defieieneies in two related areas the development of task- and operation-speeifie hazard analyses and the eonduet of monitoring programs designed to eharaeterize employee exposures to hazardous materials. These defieieneies are dis-eussed in more detail below. 

The contractor at Site H had established area and personnel sampling consistent with HAZWOPER requirements. A photo ionization detector (PID) and a real-time aerosol monitor (RAM) were used on a daily basis to screen for potentially hazardous levels of contaminants. On a weekly basis, personal air samples were collected and submitted for laboratory analysis. PPE requirements, however, were often not based on this data because the oversight agency had established inflexible minimum PPE requirements. The audit team found many of the PPE requirements on Site H to be excessive in light of site monitoring data and hazard determinations. 

Site H was the only site at which the contractor had implemented comprehensive and effective site control elements. The Site H contractor had established site work zones, a buddy system, and site communication procedures consistent with 1910.120(d). This contractor had also established exclusion zones and contamination reduction zones to control migration of site contaminants to clean areas of the site when work within these areas introduced the potential for exposure to hazardous contaminants. The audit team supported this contractor s use of flexible and temporary work zone boundaries based on monitoring results and hazard determinations. 

The audit team took wipe samples from the surfaee of the disearded PPE and analyzed them for metals, pestieides, and SVOCs, but found no deteetable eontamination. The Site I eontraetor, however, did not have additional sampling data from different days or varying eireumstanees to verify that on a eonsistent basis, eontamination was not being spread to elean areas of the site beeause of the laek of deeontamination operations. 

The Site E eontraetor had established fixed work zones based on the potential for exposure but adjusted the barriers to aeeommodate eertain aetivities, sueh as thermal unit maintenanee. Wliile adjusting work zone boundaries aeeording to the potential for eontamination is aeeeptable, worker behavior indieated eonfusion about the zone boundaries and assoeiated work praetiees and PPE requirements. In addition, the audit team observed Site E workers leaving the exelusion zone without performing required deeontamination proeedures. 

Contractors at Sites E, H, and J had documented confined space programs but had not fully implemented these programs. The Site H contractor had established a permit-required confined space entry program consistent with HAZWOPER requirements however, onsite procedures were not completely consistent with the written program or OSHA requirements. For example, the confined space permit form used at Site H was not the form included in the written program. The audit team also found evidence that employee training was insufficient for safe... 

The seleetion of eflfeetive audit team members is eritieal to the sueeess of the program. Team members should be ehosen for their experienee, knowledge, and training and should be familiar with the proeesses and auditing teehniques, praetiees and proeedures. 

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits. 

A trained audit team, consisting of one or more persons audits the fety... 

The audit team members are selected for their experience, knowledge, training, familiarity with the procei i and auditing techniques, practices, and procedures. The size of the team denends... 

All ISO/TS 16949 audit teams including surveillance shall consist of lATF-qualified auditors. The Team Leader has to ensure that the audit team comprises only lATF-qualified auditors - hence if the CB has only two qualified auditors, the audit days have to be extended. 

For consistency at least one auditor of the initial audit team should participate in all visits of a three-year cycle. By using the word should, the requirement is rendered non-mandatory and hence acknowledges that people may leave CBs. 

The level of team members effectiveness depends on skills, experience, and the guidance they follow. A formal audit protocol provides the user with step-by-step instructions on how to conduct the audit, and thus can be used by less experienced auditors. Use of less formal assessment guides such as topical outlines requires more experienced auditors. Either way, the skill level of an audit team must be sufficient to enable members to ... 

Be certain that spill hazards are reviewed as part of the plant s internal audit program. Audit-team members should be trained to look for deficient containers, fall hazards that also can contribute to a spill, improper container labeling, and other potential hazards. Major causes of chemical spills are ... 

The project will progress in stages, beginning with a waste audit carried out by an audit team. The audit team consists of a waste audit expert, a sector specialist, a financial expert, an economist/ marketing expert, and an expert in product life-cycle assessments. The audit team also supports the project in its different stages. 

The audit data can now be evaluated, resulting in audit findings (i.e., conclusions both positive and negative). The audit team should confirm that sufficient data has been collected to support each finding. Additional data may need to be gathered if the team decides a preliminary finding needs to be strengthened. The conclusions drawn from the data evaluation should be a team consensus. 

Those leading audit teams should be experienced in the audit process. All auditors should have some training in the audit process, particularly in the gathering of data ... 

Audits may be conducted by one person experienced in the audit process with general knowledge of the type of facility to be audited. More often, audits are conducted by a small team of people. The audit team should not be associated with the program or facility under audit in order to provide an unbiased independent perspective. 

For companies having multiple plant sites, it can be useful to staff the audit team with competent people from other sites. In this way, the audit process can provide an outside perspective and a learning experience for the audit team members. 

Although not essential, it may be helpful to include a member of the original incident investigation team on the audit team to help assure that the final implemented actions address the original issues in an acceptable manner. 

All staff present were told that it is highly likely that they will be interviewed by the auditing team. I hope that each person will take the information they learned in the staff development back to their campus and share it with their principal, special education staff not present, and the general education teachers. 

The main requirement of the audit team is to collect objective evidence throughout the audit task by means of interviews with the staff, examination of documents, and observation of activities and conditions at the work or site. The following methods may be used as a guideline or as appropriate to your company s operations to achieve the audit aim ... 

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