Auditing Safety Performance

In order to monitor the success of a safety program, both a successful auditing program and quality safety metrics are needed because audits are another technique used in the evaluation and data collection process of the program. An audit or inspection is the monitoring function conducted in an industrial organization to locate and report existing and potential hazards, or man-environment systems or conditions, that have the capacity to cause accidents or illnesses in the workplace (Petersen 1998). 

Compliance of the safety process to laws, regulations, and company policies and procedures is measured effectively by audits. Self-audits can be effective, if done with objective honesty. More than 85 percent of employers in a recent Occupational Safety and Health Administration survey said they conduct voluntary self-audits of safety and health conditions in their workplaces (HE Solutions 1999, 12). With a 60% increase over an 18-year period in the number of organizations indicating they conduct audits, nearly 90 percent of the respondents indicated they had conducted an audit in the past 12 months (HE Solutions 1999,12). Reasons for conducting these audits include the need to reduce accidents, to do what is considered right for worker safety and health, and to ensure OSHA compliance. Additional motivators for organizations to conduct audits include decreases in injury rates, improvement in insurance rates, and mitigating fines from OSHA violations. 

Management has the ultimate responsibility for auditing, but should get as many people involved as practical in the auditing process. Foremen, supervisors, safely committee members, safety engineers, and plant managers are all potential inspectors. 

Another key characteristic of the audit instrument is that of reliability. If an instrument is reliable, it should provide the same results when administered multiple times at the same time. A key factor that can influence the reliability of the audit instrument is the auditor completing the instrument. If two auditors using the same instrument and the same time complete an audit, one would expect to obtain the same findings. Factors that influence how one auditor may obtain results that are different from another in this situation include the wording of the audit items, the instructions provided, and the auditor training and understanding of the audit process. 

Companies can define the scope and focus of the audit in terms of organizational, geographical, functional, and compliance contexts (National Safety Council 1997,102). These boundaries include departments within the organization, activities, and safety areas such as fire protection, industrial hygiene, and machine guarding. The audit instrument should provide the auditor with a thorough understanding of the scope of the audit process. This would ensure that areas that need to be addressed are not bypassed. The audit protocol is the auditor s plan to accomplish the objectives of the audit (National Safety Council 1997,107). The protocol provides the auditor with instructions on the locations to audit and the areas that should be addressed. Descriptions of the situations that indicate compliance and non-compliance with the audit protocol should be included with the audit items. 

---

The technical package may specify a scope and frequency for periodic audits and performance criteria that could lead to changing the audit frequency. It may be a general safety and environmental performance audit or a special audit for items such as raw material storage and handling, quality control methods and documentation. The proprietary nature of a process or product or the complexity of the toll could be a reason to establish a more frequent audit schedule for certain tolls. Audits can also be conducted to follow-up on previously identified shortcomings to document that they were addressed properly. 

To ensure that the safety program is working, most companies have a safety policy follow-through. This includes monthly safety meetings, performance reviews, and safety audits. The monthly safety meetings include a discussion of any accidents (and resolution of prevention means), training on specific issues, inspection of facilities, and delegation of work. Performance reviews within the company for all employees must have a visible safety performance component. 

Pre-Startup Safety Review (PSSR) Audit check performed prior to equipment operation to ensure adequate PSM activities have been performed. The check should verify (1) Construction and equipment is satisfactory, (2) Procedures are available and adequate, (3) A PHA has been undertaken and recommendations resolved, (4) The employees are trained. 

However, not only the technical aspects will finally have to be addressed, but the whole range of scientific and business, regulatory, safety, performance, and quality requirements will have to be included, amongst which the existence of an audit trail may be cited as an important part. 

Caps are established, with margins of safety, and completed facility TDML plans and strategies are provided to the EPA for approval or disapproval. The time defined within a TDML plan does not necessarily have to eqnal 1 day, and a reserve for future polluting activities is typically comprehended. Approved agencies or parties will regularly audit site performance against a facility s TMDL plan. 

Once again, audits and performance assessments should start from the safety constraints and design assumptions and rationale. The goal should be to determine whether the safety constraints are being enforced in the operation of the system and whether the assumptions underlying the safety design and rationale are still true. Audits and performance assessments provide a chance to detect whether the behavior of the system and the system components still satisfies the safety constraints and whether the way the controllers think the system is working—as reflected in their process models—is accurate. 

Setting up a safety information system for a single project or product may be easier. The effort starts in the development process and then is passed on for use in operations. The information accumulated during the safety-driven design process provides the baseline for operations, as described in chapter 12. For example, the identification of critical items in the hazard analysis can be used as input to the maintenance process for prioritization. Another example is the use of the assumptions underlying the hazard analysis to guide the audit and performance assessment process. But first the information needs to be recorded and easily located and used by operations personnel. 

Because of the emphasis given to them in discussions with safety professionals, two performance measurement systems deserve further comment. Scheduled safety audits are performed in eveiy superior performing company. Through a formal process, they provide management with a determination that expectations are or are not being met. In that process a systems aura prevails — an aura of plan, do, check, and improve. 

Directing, developing, or helping to develop management accountability and audit programs tliat assess safety performance of entire systems, organizations, processes, and operations or their components and involve both deterrents and incentives. 

In Chapter 24, Measurement of Safety Performance, it is said that precise and certain measures of safety, health, and enviromnental performance are difficult to obtain. Nevertheless, audits can be highly effective measures of the quality of hazards management in place if they are well conceived and well done. I suggest keeping in mind the observation made by Kase and Wiese concerning the purpose of a safety audit ... 

---