Prevention program audits

All pollution prevention programs start the same - with an audit. The objective of an audit is to gather information aimed at developing a baseline description of the operations. Once we understand how much the costs of compliance to air and other pollution media are, then we can apply engineering tools and management practices to reduce these costs. 

The focus of MANAGER is somewhat different, in that it was primarily developed to provide a numerical output for use in risk assessment. Nevertheless, the qualitative dimensions included in the audit trail will undoubtedly provide information which can be used as part of an error prevention program. 

Prevention program safety information hazard review operating procedures training maintenance incident investigation compliance audit. 

A Pre-Audit Safety Awareness Survey, distributed through line management, asks employees about their knowledge of and attitude toward the location s safety and loss prevention programs. 

Internal safety system audits should take place every 6 months by a trained team of internal accredited auditors. The audit is not merely a safety inspection. A safety audit provides the means for a systematic analysis of each elanent of a loss prevention program to determine the extent and quality of the controls. It is a critical examination of all, or part, of a total safety operating system, and it is a management tool that measures the overall operating effectiveness of a company s safety and health program. 

A good practice many facilities have adopted is the use of a standard protocol for performing self- and third-party audits of their process safety management system or RMP prevention program performance. This chapter provides some examples of ... 

One way to facilitate the audit process is when individual elements of PSM or the RMP prevention program can be scheduled for audit by quarter to ensure all elements of the PSM system are audited every three years. This continuous auditing cycle maintains employee awareness of the overall PSM system and reduces personnel requirements. 

In developing the audit program for your specific facility or operation, you should clearly establish the scope of the audits, composition of the audit team, their respective roles and responsibilities, and the on-site and post-site audit procedures. The proposed audit program should be reviewed with appropriate managers for their buy-in since you will be working with them to implement specific corrective and preventative programs following the audit. 

Management Operating policies and procedures Training for vapor release prevention and control Audits and inspections Equipment testing Maintenance program Management of modifications and changes to prevent new hazards Security... 

Preventive measures include everything from safe work practices to training programs, good housekeeping, regular audits, administrative and engineering controls, and chemical-protection equipment. 

A recent study of programs for existing facilities of several companies reveals that a pollution-prevention initiative will tend to progress in stages.9 After a training period and an audit of the wastes in the process, the first reduction efforts emphasize the simple, obvious, and most cost-effective alternatives and are generally directed at extrinsic wastes. 

Emerson Electric, a manufacturer of power tools, implemented a Waste and Energy Management Program to identify opportunities for pollution prevention. An audit resulted in the following actions5 ... 

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. 

The fire protection audit element can be conducted with the scope of the audit focused only on fire protection. However, many companies in the process industries audit fire prevention as an integral part of the overall loss prevention effort and combine it into audits with other programs. 

Audits are an important part of safety and loss prevention. Ideally, they are educational for the plant being audited. In addition, well-planned and well-executed audits will detect deficiencies in the program and point out situations where performance deviates from accepted standards. 

A well-conducted program of internal self-audits is important to a site s overall safety and loss prevention efforts. The discussion in this section is applicable to internal audits as well as to external audits conducted by audit teams from other Dow units. 

For medical devices, inspectors expect to see a process improvement program in place encompassing all activities within the supply chain, including the systems that support it. Activities that would provide evidence that such a program is in place include the implementation of documented processes such as Corrective and Preventative Action (CAPA), self-inspection, and internal audits." Organizations should ensure that where an SOP has been put in place to initiate a process improvement activity, the SOP is adhered to. For example, if a quality audit SOP states that all areas shall be subject to audit at least once every 2 years, then inspectors will expect to see evidence that this has been the case. Failure to do so is likely to result in a citation similar to that issued to Krieger Medical, Inc. ... 

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