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Safety Inspection or Safety Audit?
This issue has come up before and I want to tackle it in this episode. So some coaching going on in this podcast episode and post. First, let’s get the definitions out of the way:
- Inspection: Physical checks for acceptable conditions conducted at the direction of regulatory requirements, guidelines, policies, procedures, etc. outlined in your overall safety manual or as a part of a safety management system.
- Audit: An independent review of the effectiveness, implementation and compliance with established regulatory requirements, guidelines, policies, procedures, etc. outlined in your overall safety manual or as a part of a safety management system. It is important to note that independent does not necessarily mean from an outside organization. Independence means not being responsible for the activity being audited or free of bias and conflict of interest. This means you cannot audit your own work.
So think of an inspection as a specific physical check to see if a tool, vehicle, machine, etc. is in safe working condition. Like a forklift inspection; before each shift operators are required to conduct an inspection to ensure it is in safe condition. Always provide adequate checklists to ensure consistency of inspections and to allow a trend analysis to be developed t look for areas of improvement during any program audits.
An audit is a review to see if inspections are being done and to check the quality of the inspection results. Or, inspections are tactical and audits are strategic. Most folks focus on the tactical activity of performing inspections. They have checklists, cards, etc. Our industry needs to place more emphasis on the strategic review of safety as well. I would encourage you to go one step further and apply a management system approach to these activities.
To help illustrate the importance I will use the ANSI Z-10 Standard for Occupational Safety and Health Management Systems (OHSMS) as an example. The OHSMS cycle ANSI lays out entails an initial planning process and implementation of the safety management system, followed by a process for checking the performance of these activities and taking appropriate corrective actions. The next step involves a management review of the system for suitability, adequacy, and effectiveness against its policy and this standard. At a high level this is an audit of the OHSMS.
It is worth noting that ANSI/AIHA® Z10 focuses primarily on the strategic levels of policy and the processes to ensure the policy is effectively carried out. The standard does not provide detailed procedures, job instructions or documentation mechanisms. Each organization must design these according to their needs. This would be things like inspections: what to inspect and how often.
In a management system approach there is an emphasis on continual improvement and systematically eliminating the underlying or root causes of deficiencies. For example if an inspectionfinds an unguarded machine, not only would the unguarded machine be fixed, but there would also be a systematic process in place to discover and eliminate the underlying reason for the deficiency. This process might then lead to the goal of replacing the guards with a more effective design, or to replacement of the machines themselves so the hazard is eliminated. This systematic approach seeks a long-term solution rather than a one-time fix.
To see if this is being done effectively, an audit must take place. You would review how many inspections are being done, total number of inspections resulting in findings, number of findings resulting in root cause analysis and corrective or preventative actions (CAPA).
So I want to give you 3 criteria you need to use to conduct an audit of any aspect of your safety management system. I call it the 3 P’s:
- Paper: Look at any written programs, instructions, policies, procedures, etc. and determine if they are adequate enough for the area they address. HAZCOM is an example; review the written program to ensure it meets the minimum OSHA requirements as well as the SDS index. Does the program check all the boxes? When was it last reviewed? Who has access to it?
- People: Interview workers to determine their level of understanding of the written programs, instructions, policies, procedures, etc. This also tells you a bit about training effectiveness and retention. Sticking with the HAZCOM example, ask workers about chemicals in their work area, SDS location, labeling requirements, spill/clean-up, etc.
- Places: Go out to the job site or production floor and look for evidence that the written programs, instructions, policies, procedures, etc. are being followed. For HAZCOM, look for labels-are they worn, missing, are drums labeled? Are SDS books up to date? Placed in the proper location? Spill kits?
So you can clearly see the benefit of the three P’s when auditing your safety management system. Always extend your audit across all three P’s: Paper, People, Places. This will ensure you have done a proper and thorough audit.
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