13.4.1 Responsibilities of Personnel Involved in the Audit Process
The key roles in the Audit process are the Auditor and the Audit Authority.
The Auditor is the person responsible for leading the Audit.
The Audit Authority is the person to whom the Audit report is presented, and who is responsible for corrective actions. The role of the Audit Authority is vital in ensuring that corrective actions are allocated to individuals and completed.
Their responsibilities are:
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The Auditor
Auditors are to have satisfactorily completed the Permit to Work Auditing Course during the previous 4 years to the audit, and have been involved in using or maintaining the Permit to Work System in the last 12 months.
Auditors are to prepare the Audit, conduct the Audit effectively and prepare an Audit Report, which sets out the findings in a concise and readable manner.
Auditors are not responsible for rectifying any problems found. This is the responsibility of the Audit Authority and the Department(s) being audited.
Auditors are responsible for:
Defining the Audit objectives and communicating them to people involved.
Carrying out the Audit at the stated time, making sufficient time to do the Audit properly, and Auditing in an alert and courteous manner.
Concentrating on the objectives of the Audit, and not being side-tracked.
Carrying out all the checks required by Audit documentation.
Preparing a written Audit Report.
Submitting the Report to the Audit Authority at the correct time.
The Audit Authority
The Audit Authority is to ensure that Audits take place in accordance with the Audit Programme, and is to make time to analyse and action the results. The Audit Authority is responsible for:
Ensuring there is a published Audit Programme.
Ensuring there are sufficient trained Auditors for the area.
Ensuring Audit Reports are analysed and actioned.
Ensuring actions are properly tracked and reviewed.
13.4.2 Types of Audit
Auditing of the PTW System is done at two separate levels. Table 13.1 defines the Audit Authority, Auditor and Audit Programming and Training Requirements for Level 1 and 2 Audits.
Level 2 – 3-6 Monthly Audits
These audits look at the operation of the complete PTW system in an Area, including the performance of those who operate the system. The audit is likely to last 1-2 days. It may be done by auditor(s) from within the area, or by nominated auditors from other areas.
The Audit Authority is to issue a yearly programme stating when Level 2 audits should be done, and who will be the Auditors. Level 2 Audits should be carried out between 2 and 4 times per year in each Area. The Asset Manager for the Area is responsible for defining the audit frequency within these limits, depending on the level of Permit activity in the Area.
The Audit is to include:
Checks on the operation of the PTW System and the performance of the personnel required by Audit Forms A -E.
Any other checks on the system considered necessary by the auditor.
Table 13.1: Audit Structure
Audit Report is Presented Area Operations Team Leader UOP Boundary within which
Audit is Conducted Area Company
Lead Auditor Operations Team Leader or Area
Coordinator Qualified Nominated
Training of Auditors Each to have successfully completed the PTW Auditors Course Publication of Audit
Programme Audit Authority to produce annual
programme MSE/53 to schedule audit
requirements
Presentation of Findings Report submitted within 1 week Report submitted within 2 weeks
Review of Corrective
Actions Operations Team Leader UOP/7
Archivist Area Coordinator MSE/5
Level 1 - Corporate Audits
These audits examine all aspects of the operation of the Permit to Work system. They are carried out to ensure that the Permit to Work is working effectively. The audit is likely to last 7 -10 days, depending on the size and complexity of the operation. It is to be done by the Corporate HSE Department.
These Audits are to include:
A check of the frequency, standard and results of Level 2 Audits.
Audits of the system and personnel, using the standard audit forms, to provide an independent view of whether system requirements are being complied with.
Checks on whether the nominated Custodians for the various aspects of the system are undertaking their stated responsibilities and whether these arrangements are adequate.
An examination of PTW Training.
A review of whether the PTW documentation is accurate and adequate.
A review of understanding of, and attitude to the system, by personnel operating it.
Examination of arrangements for the appointment of signatories, and whether satisfactory controls are in place.
Examination of the arrangements for system review.
Any other checks on the system considered necessary by the auditors.
Any of the standard audit forms may be used to assist in the audit.
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13.4.3 Audit Organisation Audit Numbering
Each Level 2 Audit is to be given a 3-part reference number on the Audit forms, including:
A site or department identifier.
The last two digits of the year in which the Audit is done.
A number from 1 upwards each year to identify the individual Audit.
These 3 parts are to be combined into a single identifier e.g. Fahud/98/03.
13.4.4 Conduct of the Audit
To provide a proper assessment of the operation of the PTW system, the Audit must be recognised as important by both Auditors and those being audited. Those who are subject to Audit should show active participation by co-operating with the Auditor in giving time to the Audit, when required. They should provide the Auditor with sound and reasoned responses to Audit questions.
In order to achieve this, the importance of Auditing is stressed during PTW training courses.
This importance should also be emphasised during Safety Meetings, particularly those where corrective actions are reviewed.
13.4.5 Audit Reporting Audit Reports
The essential features of audit reports are that they should be brief, concentrating on significant finding of the audit.
Separate non-compliances from observations.
Recommend corrective actions and action parties.
Reports on Level 1 audits should be submitted to the Audit Authority for approval of the recommended actions and action parties.
Be signed by the Audit Authority. It then becomes a formal statement of actions required.
Be distributed to all action parties the Area Coordinator and DTL of the Audited Area together with:
o Audit Authority.
o Area Coordinator.
o Area Safety Supervisor.
o PTW System Custodian.
Corrective Action
In assessing whether an audit finding is a non-compliance, requiring corrective action to be taken, auditors should bear in mind the definition of a non-compliance, which is:
“A deviation of unacceptable magnitude from the defined standard which, unless corrected, may lead to a breakdown of the system.”
Where auditors find isolated minor non-compliances, which are not repeated either by the individual involved or in the area audited these should be pointed out to the individuals involved, but they should not constitute non-compliance.
Non-compliances should be categorised under headings similar to “Table of Contents” of this procedure, covering topics such as:
PTW System Operation.
PTW System Requirements.
PTW System Documentation and Hardware.
PTW Training.
HSE Awareness.
Competency.
Motivation.
Information and Communication.
Management and Supervision.
Management of Contractors.
The Audit Authority is to ensure that all corrective actions required by Audit Reports have been properly actioned and are subject to regular monitoring.
13.4.6 Audit Archiving
Audits for each Audit Area are to be kept in an archive to ensure that:
A record of corrective actions required is kept.
Other Auditors can examine the records and ensure that Audits have been done correctly and that corrective actions have been taken.
Archives are to be managed as follows:
For each area, a post is to be nominated to maintain the Audit archive.
The archive is to contain the Master Copy of all Audits for the Area.
The Audit Report (Audit Form A), together with all supporting Audit forms and documents collected during the Audit are to be archived.
The Archive file should include a list of all Audits it contains.
The Archive is to be kept in a secure location.
Audit reports should be held in the Archive File for 12 months.