How to Conduct Safety and Health Audits
Systematic evaluation of your safety and health situation is an important facet of your program. Don’t wait for accidents to happen before you investigate and inspect. Safety and health consciousness tends to slip, and it’s your job to be sure that that doesn’t happen. A well-prepared and well-executed safety audit/inspection program can make a substantial difference in accident prevention.
What’s the objective of a safety inspection program? The discovery–through specific, methodical auditing, checking, or inspection procedures–of conditions and work practices that lead to job accidents and industrial illnesses, then reporting these for correction.
Stated more positively, it’s checking to see that things are in good shape. This is at the heart of successful accident-prevention programs fostered by forward-thinking safety management. Most organizations with successful safety programs have well-organized safety audit programs. It’s just that simple.
In addition to its direct accident-prevention role, the inspection program:
· Reduces the possibility of important items being overlooked.
As one plant engineer put it, safety inspection tours are like preventive maintenance–every piece of equipment wears down and deteriorates over time–and those pieces of equipment have to be checked regularly. Similarly, employee work procedures fall into routines over time–some of them unsafe routines–and these practices need regular re-evaluation to make sure that safe work procedures are followed.Here’s what you’ll find in this guidance document–we’ll discuss:
· Suggestions on how to prioritize the results of safety inspections considering the time and funds allocations of your firm
· What management must understand about a safety audit program.
· A comprehensive checklist of potential manufacturing, service, maintenance, and office hazards from which you can tailor a safety checklist for your organization.
What Are the Purposes of Effective Safety Inspections?Why should you be doing audits and inspections? Here are a number of objectives:
· Involve many more employees in the safety program
· Help sell the safety program within the organization thereby enabling you to:
— Re-evaluate the safety standards of the organization
— Compare safety results against safety plans
— Gauge the relative success of safety training efforts
— Anticipate problems in advance of any OSHA inspection.
Planning a Safety Audit/Inspection ProgramA good safety audit program does not come easily. The effort requires careful planning and diligent preparation. The program unfolds after you decide what you want to cover in your inspections. The following questions should be considered in laying plans for a safety audit program in your organization:
· Who will conduct the tours?
· How will the inspections be conducted?
· What type of follow-up activity will be put in place so that corrections are, in fact, made?
· Does management understand that hazards or unsafe work practices will need to be corrected and that this will require human resources, management and engineering expertise?
General vs. SpecificThe first question, experts in the safety audit field generally agree, should be: Do you want to conduct a general inspection or do you want to conduct a special type of inspection?
General inspections are considered comprehensive reviews of all safety and industrial health exposures in a given area or even a complete factory.
Special inspections (sometimes called targeted inspections) deal with specific exposures in a given unit, section, or even plantwide. Such an inspection might focus on electrical hazards in machinery used for manufacturing, or the hazards that may have generated back injuries as recorded in the OSHA 300 log or noticed during a review of workers’ compensation reports. It could involve the branch’s compliance with the OSHA Hazard Communication Standard and the development of a checklist for compliance with the principal elements of that standard.
A good inspection program can include both the special and the general type of inspections. For example, one month a program could involve a complete plant tour for safety hazards; the next month the inspection program could focus on personal protective equipment and how it is used on the job. OSHA encourages such a mixed approach, believing that a combination of the two types of programs can strengthen a plant’s accident-prevention effort.
Three Case Histories
Here’s how three organizations approached their safety inspection plans.
Small Machine Shop–Spokane
A small machine shop in Spokane decided to mix the general-type approach with an inspection checklist that focused on specific problems. Their inspection forms listed the following:
- Machinery guarding in the shop
- Welding activities
- Portable electric tools
- Safety in working around the parts cleaning tank
- Wearing goggles for eye protection
- Supervisory approval of safety work projects
- Ready access to first-aid and medical facilities
- Safety orientation for new machine-tool operators
All of this formal activity supplemented the small, daily checklist that tool and die makers and machinists made in the first few minutes of start-up at the beginning of their shifts.
A plastics injection molding plant listed an extensive checklist for machine guarding and guard repair since their manufacturing process falls under OSHA’s power press classification and its regulations. As backup to the guarding reviews, they then listed personal protective equipment as an important ingredient of their safety program–wearing specific types of gloves, eye protection, and hearing protection. They also made a careful review of lockout/tagout procedures. Since the plant was in a hiring mode, an extensive checklist on new and then transferred employee safety orientation was developed. A member of the safety committee performed the “inspection checkout” that these employees had, in fact, been trained and, most important, that they had absorbed and were practicing the training.
Do safety inspections belong in the office setting?
Absolutely! A services organization suffered its first days away from work case when an employee tripped over a computer cord, fractured her wrist, and suffered jaw and dental damage in the tumble. The organization then developed a monthly safety tour checklist that focused on the following:
- Dangers of trips and falls
- Cautions required in lifting equipment or heavy boxes
- Importance of getting help with heavy moving tasks
- Dangers in overloading filing cabinets, which could fall forward
- Dangers of falling objects
- Dangers of paper and knife cuts
- Additional special training was given to a few employees who regularly handle chemicals in the photocopying process.
Note that in these examples, safety planners all focus on specifics–specifics that translate themselves into checklists. An effective checklist is like the “eyes and ears” of your safety program.
Who Should Conduct Safety Inspections?
Before you try to answer that question, you will want to consider the complexity of the process, the nature of the inspection (general or specific), the time availability of candidate inspectors, the expected frequency of the tours, and other factors.
In some manufacturing companies, the safety committee will take the lead in inspections. In other operating units, a rotating team of supervisors, perhaps with safety committee assistance, will head the task. Most experts, however, do recommend involving the supervisor or manager. This makes it clear that line management, not the safety department, has responsibility for safety.
Inspecting complex technological operations may require specialized skills, knowledge, training, or even certification. Such inspections should be conducted only by people knowledgeable about the department of operation.
Outsiders Can Be Helpful
Outsiders may also participate in your audits. Insurance company loss-control can be helpful by coming to inspect your premises and helping you with your safety audit. This is particularly true for organizations that involve hazardous occupations. Sometimes, too, the workers’ compensation carrier will insist on plant tours from time to time to assess the safety program. Specialized vendors, like boiler inspectors, will also tour, perhaps on a semiannual or yearly basis.
And then there is the OSHA specialist who arrives unannounced to check on your compliance with specific OSHA regulations. Even if there is not a specific regulation, that specialist may want to measure your organization against the OSHA General Duty Clause that requires employers to provide a safe workplace free from recognized hazards. But most employers would like to be one jump ahead of OSHA with an effective local audit program, conducted by effectively trained inspectors using a carefully prepared general or specific checklist. Here’s how to go about developing your checklists.
What Should You Inspect for?
Most inspection programs give leading attention to hazardous conditions. That is the obvious focus of an inspection program–machinery, materials, environmental conditions, and the like that could cause injury.
Too often, though, little attention is given to unsafe acts or hazardous behavior of employees–perhaps the leading cause of injuries in the United States today. This part of the inspection program should focus on such very basic items as new-employee safety orientation, specific training on the new job for the employee, supervisory follow-up, a review of the OSHA 300 log to highlight injuries and their causes, and, perhaps the most important part, the recommendation of improved, safe working procedures when causes have been determined.
How Often Should You Inspect?
Most safety inspection/audit programs feature a variety of inspections at varying times. Many in-plant programs call for a formal monthly safety tour. Other organizations focus on a weekly round by the safety committee. Outside inspectors may show up only annually or twice yearly, depending on their function.
These special inspection activities should be in addition to:
Frequency will focus on need and, sometimes, on how bad your situation is. An Indiana manufacturer with a days away from work rate of twice the industry average cranked up an inspection approach that involved:
· Preview of the reports and follow-up action designated by the management safety committee.
Announced or Unannounced?Should safety inspections be planned or should they be unannounced? There are differing views on this subject. The planned inspection has the advantage of thoroughness, of a scheduled activity with the auditors focused on doing the job and doing it thoroughly. But word gets around the manufacturing floor that “the inspectors are coming.” Employees try to show off their departments and equipment in the best fashion. Unsafe work practices may not be detected.
The unannounced inspection is most likely to find conditions and work practices in a normal, everyday mode of operation. Unsafe work practices are more likely to be observed and noted on an unannounced tour.
Making Safety a Priority
How do you give inspection items some kind of priority status? With tight maintenance budgets and workforce manning limitations, it is not always easy to give safety items the priority they deserve. This is especially the case in these days of pared budgets at the plant level.
A number of companies successful in the safety field have developed what they call “priority listings” for the maintenance work, and the management and supervisory follow-up that needs to be done as a result of a safety inspection tour. Some companies list as “red” those priorities that require immediate attention with the color amber given to items of secondary importance.
Other organizations use the U-I-R approach, classifying these items according to their importance with the designations of Urgent (U), Important (I), or Routine (R).
Still other organizations give a l, 2, or 3 priority to safety recommendations, depending on the relative importance of an item. Some companies have approached the mass by developing an A, B, or C approach to these recommendations. See the accompanying page for one company’s hazard priority classification system–an approach that could perhaps be applied in your organization.
What Management Should Understand about Safety Audits
Even though safety audit reports are internal company documents, management should understand that these safety inspection reports may be subject to review by outside agencies such as OSHA or subpoenaed in a court case.
The importance of management understanding and support for an audit program before embarking on such a program can not be overemphasized. Don’t start a safety an health audit program unless your management is fully prepared to correct unsafe conditions and work practices uncovered in these inspections, including setting aside money and the manpower to do the job.
The format of audit reports should also be prepared carefully and reviewed by legal counsel to maximize the possibility of achieving a privilege against disclosure should an outside agency such as OSHA demand to review these internal reports.
The audit format should avoid broad, encompassing questions which are likely to produce broad, general recommendations; specific audit questions will likely result in more focused recommendations.
Safety auditors should receive training in how to audit and how to focus on the specific item to be recorded, avoiding exaggeration or oversimplification. Supportive paperwork should show how the recommendations were handled and brought to conclusion–either corrected, prioritized for future action, listed for capital allocation request, etc.
OSHA’s Policy on Voluntary Self-Audits
OSHA has developed a policy describing the Agency’s treatment of voluntary employer self-audits that assess workplace safety and health conditions, including compliance with the Occupational Safety and Health Act. The policy provides that the Agency will not routinely request self-audit reports at the initiation of an inspection, and will not use self-audit reports as a means of identifying hazards upon which to focus during an inspection. In addition, where a voluntary self-audit identifies a hazardous condition, and the employer has corrected the violative condition prior to the initiation of an inspection (or a related accident, illness, or injury that triggers the OSHA inspection) and has taken appropriate steps to prevent the recurrence of the condition, the Agency will refrain from issuing a citation, even if the violative condition existed within the six month limitations period during which OSHA is authorized to issue citations. Where a voluntary self-audit identifies a hazardous condition, and the employer promptly undertakes appropriate measures to correct the violative condition and to provide interim employee protection, but has not completely corrected the violative condition when an OSHA inspection occurs, the Agency will treat the audit report as evidence of good faith, and not as evidence of a willful violation of the Act.
One Company’s Hazard Priority Classification System
On the safety inspection tour, classify all reported items with a PRIORITY LISTING of 1 or 2 or 3 or 4, as explained below:
The most serious type of unsafe condition or unsafe work practice that could cause loss of life, permanent disability, the loss of a body part (amputation or crippling injury), or extensive loss of structure, equipment, or material.
Correction Plan: Determine responsibility for repair, replace immediately, or remove from service. Determine basic cause of the problem and assign responsibility for correction and time deadline for correction. Review item at weekly management meeting and safety steering committee meeting and set firm deadlines for correction.
Unsafe condition or work practice that could cause serious injury, industrial illness, or disruptive property damage.
Correction Plan: Complete repairs or corrections or develop definitive training or retraining plan, assign responsibility for correction immediately and a deadline for correction, all not to exceed 30 days’ duration. Review at bi-weekly management safety steering committee meeting.
Unsafe condition or unsafe work practice that might cause a recordable injury or industrial illness or nondisruptive property damage.
Correction Plan: Give priority on regular maintenance schedule, advise supervisors or managers in writing or develop training programs to overcome the problem. Assign responsibility for correction and set time frame for correction.
Minor condition, a housekeeping item or unsafe work practice infraction with little likelihood of injury or illness other than perhaps a first-aid case.
Correction Plan: Work into regular maintenance schedule, advise supervisors to retrain workers involved. Time frame for correction set and responsibility assigned.
The Checklist: Critical Component
Most management groups readily accept the importance of safety inspections and audits. But too many hand the tour committee a clipboard and pencil and say, “Here, take notes if you see any problems.” This is a waste of time and energy. The committee roams about, not really focusing on what to look for.
However, once an item is on a checklist, it can’t be ignored–even if checking it out promises to be difficult or unpleasant. For instance, without a checklist, you won’t find inspectors crawling under machinery or performing particularly dirty tests. But with a checklist, they don’t have much choice.
In the checklist listed below are a number of elements in typical manufacturing, maintenance, or machine shop operations and in office or service settings that should aid you in developing a safety inspection tour checklist tailored to your operations and needs.
In the checklist, pick from the detailed list those items that fit your needs so that you may put your inspection teams to productive work as the “eyes and ears” of your safety improvement efforts.