Safety audits or comprehensive safety management program assessments can help determine the efficacy and thoroughness of a company’s hazard abatement and overall safety and health strategy. They can also check an organization’s level of compliance to OSHA standards, voluntary industry consensus practices as well as other applicable codes and regulations.
According to Chuck Kelly, president of Kelly Consulting and Mediation Services, a leader in comprehensive safety audits for line construction and the utility industry, “A comprehensive safety management program assessment requires the evaluation of core content, the effectual communication of program elements, the perception of the workforce, and the application of safe practices on the job. Assessments that quantify all four components and provide information and recommendations needed will improve a company’s application of effective program elements, their communication with employees and its overall safety culture.”
Internal vs. third-party audit
Assessments can be done internally or by an independent third party, typically a qualified safety consultant. Third-party evaluations have grown in popularity, which is largely attributable to attempts at OSHA reform legislation. If enacted, these proposals would have required the use of third parties in tasks previously conducted by OSHA. Some industries require safety audits be executed by third-party professionals.
If an employer decides to conduct an internal comprehensive safety management program assessment, they should choose three to five evaluators from different sectors of the company. It is imperative that the individuals executing the process don’t work in the department being evaluated to help ensure that auditors have an unbiased and objective point of view.
Each individual should review all written safety programs, training resources and any other pertinent materials prior to the assessment. They also should be familiar with all relevant OSHA, National Fire Protection Association (NFPA) 70E and lockout/tagout requirements, as well as building and fire codes, state and local compliance requisites and industry best practices.
During the safety assessment process, evaluators review, observe and audit different materials and scenarios for the purpose of occupational safety and health and hazard identification. They can survey employees about their general safety knowledge, environmental hazard awareness and practices and procedures for a variety of situations and circumstances.
Work site evaluations may measure compliance to OSHA standards pertaining to ergonomics, respirators, hearing conservation, blood-borne pathogens, electrical safety or use of personal protective equipment (PPE). Ergonomics is often a focus due to its relationship to repetitive or cumulative stress disorders. The goal of ergonomics is to modify tasks, workstations, tools and equipment to minimize the impact on workers. Poorly postured positions and work practices can easily be observed during a walk-through.
Basic or in-depth
Comprehensive safety management program assessments can be basic and based on compliance with OSHA standards and National Safety Council guidelines, or can be more in-depth. For example, the Geneva-based International Organization for Standardization’s ISO 45001 is one of the world’s highest levels of certification for occupational health and safety. The standard was issued to protect employees and businesses from hazards causing irreparable harm. This certification replaced Occupational Health and Safety Assessment Series (OHSAS) 18001 and is considered to be the gold standard in workplace safety and health. OHSAS 18001 was a British standard that many organizations used as a benchmark. Compliance allowed employers to show that they had an effective safety and management system in place.
Conducting an annual safety audit has the potential to produce misleading results, since supervisors, managers and other workers have the opportunity to prepare for the audit and work environments may therefore seem safer than they actually are. Experts recommend safety audits be an ongoing process throughout the year.
Safety management program assessments are intended to determine how effective an organization’s safety and health programs are. These audits should not be executed in lieu of regular facility safety inspections. Facility inspections conducted to identify hazards in the workplace should be done weekly by supervisors and on a monthly basis by management.
Every comprehensive management program assessment should answer four questions.
Does the program cover all regulatory and industry best practice requirements?
Are the program requirements being met?
Is there documented proof of compliance?
Is employee training effective?
Answering these questions will help evaluators determine the appropriate follow-up comments, recommendations or corrective actions.
Employers should inform any impacted departments, managers and supervisors one week in advance of undertaking a comprehensive safety assessment. Each should be instructed to make all records, documents and procedures available to auditors.
Employees should ensure that they have addressed corrective actions or safety recommendations from previous audits and brush up on relevant documents, inspections and training requirements. It can also be helpful to understand the scope of and reason for the audit. Was it brought on by an accident? Failed inspection? Whistleblower complaints?
Once evaluators embark on the fact-finding mission, it is important that assessors don’t form an opinion until all the information is gathered and reviewed. If there are multiple auditors—which is recommended—the work can be divided among team members.
A majority of safety audits evaluate using the following categories: employee knowledge, written program review, program administration, record and document review, equipment and material and general walk-through.
OSHA requires that employees are “effectively trained,” so evaluators must gauge the knowledge workers have. The level of knowledge an employee needs is dictated by the specific tasks they are responsible for. Typically, managers and supervisors should be well-versed on program administration, management and training. Additionally, they should be able to impart that knowledge to their designated employees. Evaluators can assess knowledge level through written quizzes, formal interviews or direct questions.
Next, a written program review will usually be conducted. This allows evaluators to compare the employer’s safety program to requirements for hazard identification and control, required employee training and record-keeping against the local, state and federal requirements.
The program administration portion of the safety audit reviews the implementation and management of specific program requirements. Evaluators may determine whether there is a person assigned and trained to manage a program, specific duties and responsibilities are assigned, sufficient assets are provided and if there is an effective and ongoing employee training program.
Next, the auditors will likely conduct a record and document review. They will be looking for missing, incomplete or error-ridden records and documents, which are a dead giveaway that a safety program is not being run properly. Additionally, record-keeping and documentation are often the only way to verify compliance with regulatory requirements. At this stage of the assessment, evaluators review the results, as well as recommendations and corrective actions from any previous audits.
Evaluators then inspect equipment, tools and materials to determine if they are in safe working condition and whether there is adequate equipment available. They check if PPE is used and stored properly, and that exit lights, emergency lights, fire extinguishers, and equipment for material storage and handling are designed and staged properly. Even though safety audits are not meant to be comprehensive, physical, wall-to-wall facility inspections, a general walk-through will allow evaluators to observe glaring hazards and paint a picture of the overall effectiveness of safety programs.
Once all the information has been gathered, the evaluators meet and develop a concise report of findings for each program or area. This report will include positive and negative results unearthed by the review. When the report is generated, recommendations for improvement or deficient program areas will be made and a corrective action plan should be developed in concert with the managers and supervisors responsible for fixes. Each corrective action should be prioritized based on risk and assigned a completion and review date. Records of each completed corrective action should be kept and available for review during a future audit.
Finally, it is imperative that employers publish and inform all supervisors and managers of the safety audit results, recommendations and corrective actions. Employers should acknowledge and recognize departments, teams or individuals with favorable results. Doing so will encourage those departments or employees that didn’t do well to try to be better and safer the next time around.
Implementing recommendations and making safety audit results available will likely produce some benefit in the workplace. This may include renewed or enhanced commitment to safety and health, improved employer-employee relations, increased production or quality, greater employee morale, better worker recruitment and retention and a more favorable image and reputation among customers, suppliers and the community.
If you would like more information on safety audits and improving occupational safety and health, or other workplace safety and hazard abatement, visit the OSHA website at www.osha.gov.