Conducting the Audit

Conducting the Audit

An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Utilizing the audit procedure and checklist developed in the preplanning stage, the audit team can systematically analyze compliance with the provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of the training program as part of the overall audit. The team will review the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the standard's requirements. Through interviews, the team can determine employees' knowledge and awareness of the safety procedures, duties, rules, and emergency response assignments. During the inspection, the team can observe actual practices such as safety and health policies, procedures, and work authorization practices. This approach enables the team to identify deficiencies and determine where corrective actions or improvements are necessary.

Evaluation and Corrective Action

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits.

Corrective action is one of the most important parts of the audit and includes identifying deficiencies, and planning, following-up, and documenting the corrections. The corrective action process normally begins with a management review of the audit findings. The purpose of this review is to determine what actions are appropriate, and to establish priorities, timetables, resource allocations and requirements, and responsibilities. In some cases, corrective action may involve a simple change in procedures or a minor maintenance effort to remedy the problem. Management of change procedures need to be used, as appropriate, even for a seemingly minor change. Many of the deficiencies can be acted on promptly, while some may require engineering studies or more detailed review of actual procedures and practices. There may be instances where no action is necessary; this is a valid response to an audit finding. All actions taken, including an explanation when no action is taken on a finding, need to be documented.

The employer must assure that each deficiency identified is addressed, the corrective action to be taken is noted, and the responsible audit person or team is properly documented. To control the corrective action process, the employer should consider the use of a tracking system. This tracking system might include periodic status reports shared with affected levels of management, specific reports such as completion of an engineering study, and a final implementation report to provide closure for audit findings that have been through management of change, if appropriate, and then shared with affected employees and management. This type of tracking system provides the employer with the status of the corrective action. It also provides the documentation required to verify that appropriate corrective actions were taken on deficiencies identified in the audit.