Audits, management program elements

During each audit, at least 15% of the facilities operated, with a minimum of one facility, should be audited. The facilities included in the audit should not be the same as those included in the previous audit. When sufficient deficiencies are identified in the effectiveness of any safety and environmental management program elements, the test sample size shall be expanded for that program element. 

Audit of safety and environmental management program elements (Section 12). 

Audit of Safety and Environmental Management Program Elements... 

The operators [and contractors with Safety and Environmental Management Programs (SEMPs)] should establish and maintain an audit program and procedures for the periodic audit of the safety and environmental management program in order to determine if the program elements have been properly implemented and maintained and to provide information on the results of the audit to management... 

A safety management system assessment goes beyond just audits of safety program elements where the intent is to find only errors or problems and ignore what is being done correctly. 

Periodically, the SEMP elements should be audited to evaluate the effectiveness of the program. Auditing should be conducted by qualified personnel through interviews and inspections. If audits consist < y find no deficiencies in the program, then management should conclude that... 

Training, operating procedures, management of change and audits are obvious first candidate programs and elements because these already have considerable overlap with the ISO 9000 requirements. 

Don t spend time collecting information already collected elsewhere. For instance, if your company has a comprehensive environmental management audit that looks at all environmental programs and elements, rely on these audits for that category of information. Be aware make sure to really understand what information is collected and whether it will meet your needs. 

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