Safety Groups – Advantage Program
Tom Welton
■ Objective
■ The Basics
– Principles of Auditing
■ Audit Process
– Preparation & Initiation
– Document Review – Evidence – Findings ■ Management – Management Review – Action Plan ■ Case Study
■ To provide you an introduction to the basic process of conducting an audit of your Health and Safety Management System.
■ Health and Safety Management System (HSMS)
– The documented process that fully incorporates effective risk management principles into a health and safety program.
■ The systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled
■ Workwell Audits
■ Compliance Audits (against legal requirements)
■ Combined Audits (for example, H&S and Environment)
■ Risk Audits/Risk Assessments
■ Workplace Inspections
■ Pre-start-up Inspections
■ Subject Specific – for example:
– RTW Self-Assessment
– Confined Space Audit/Assessment
– Emergency Preparedness & Response Audit
■ To provide Owner/Senior Management with objective information on which they can react to improve their health and safety activities
■ Conformity
– Conformity is the fulfillment of the audit criteria which includes requirements of an audit standard, the
workplace’s health and safety policies, practices, procedures and related documentation.
■ Nonconformity
– Nonconformity is the non-fulfillment of, or deviation from, the requirements. It is categorized as Major and Minor.
5 Steps to Managing Health & Safety
■
The 5 steps apply to
the Advantage
Program
requirements
■
The 5 steps apply to
each element of the
HSMS Review and
must be
documented/recorded
for each
■ Audit Scope
– Extent and boundaries of an audit
Note: The audit scope generally includes a description of the physical locations, organizational units, activities and processes, as well as the time period covered.
■ Audit Criteria
– Audit criteria are used as a reference against which audit evidence is measured. In the WSIB Advantage Program the criteria includes; the requirements documented in the HSMS Review Form and the firm’s health and safety
program, policies, procedures and related documents.
■ Audit Evidence
– Records, statements of fact or other information,
which are relevant to the audit criteria and verifiable. (minimum two different sources of evidence).
■ Audit Findings/Conclusions
– Results of the evaluation of the collected audit evidence against audit criteria.
Note: The audit findings can indicate either conformity or nonconformity with audit criteria.
Auditing relies on these principles to make it effective and reliable.
Key Concepts
What is Auditing
■ The systematic, independent and documented process for obtaining audit evidence and evaluating it objectively against established audit criteria
Why Audit
■ To provide Owner/Senior Management with information on which they can react to improve their health and safety activities
Key Concepts
Auditing Principles
■ Scope – extend and boundaries of an audit
■ Criteria – a set of established requirements the audit evidence is evaluated against. The criteria for Advantage firms is - HSMS Review Form and the firm’s H&S program, policies, procedures and other related documents.
■ Evidence – records, statements of fact or other information, which are relevant to the audit criteria and verifiable (minimum two sources of information)
Key Concepts
■ An audit is conducted in a systematic manner and requires preparation
■ Document Review collects information to help determine if the audit criteria are being met by the firm
Key Concepts
■ There are multiple sources of evidence: documents, records, interviews and observations
– Auditor(s) need sufficient information before it is considered evidence
– Recorded evidence is evaluated against established audit criteria to determine objective audit findings
– Finding of conformity or nonconformity (major or minor)
■ Nonconformities are situations where a requirement clearly has not been fulfilled with evidence based on objective facts
Key Concepts
■ The audit report can be recorded on the HSMS Review Form
■ Other styles of audit reports can be used, as long as they include all nonconformities found and relate it to the criteria requirements
■ Report any commendable HSMS findings
■ Management Review can be formal or informal
■ Owner/Senior Management must understand and agree to the
Key Concepts
■ All nonconformities are included and initiated in the action plan
■ Conformities can be included in the action plan for continual improvement
■ Resolving nonconformities and verifying they are resolved are done after audit activities
The Audit Process
INITIATING CONDUCT THE AUDIT ACTION PLAN Document Review Evidence Findings■ Management assigns the qualified auditor(s)
■ Develop an audit plan which includes:
– Objectives, Scope, Criteria, Schedule
■ Resources:
– Time
– Audit support (team)
– Health and Safety Equipment (PPE)
– Floor Plan, Equipment List, Work room
– Audit working documents (audit notes/sketches/interview notes etc.)
■ Communicate the audit activity to appropriate workplace
parties
Documents and Records
■ A document may be a policy, a procedure, a work instruction, a form, or other written information, that generally gives direction.
■ A document is current, active and changeable.
■ A record is dated, historical, and unchangeable. (An obsolete document may become a record).
■ First step in Conducting the Audit
■ Establishes initial conformity to the audit criteria
■ Determines other types of evidence the auditor(s) will sample
Policy System Procedures Operating Procedures Work Instructions Level 2 Docs
5W’s & H of system Typically addresses each WSIB HSMS Requirement “Big Picture” (may be
organized by “processes”)
Document Review
Level 1 Docs
What? (some why?)
H&S Policy Statement
H&S Policy Manual (optional)
Level 3 Docs - more details of 5W’s & H Level 4 Docs detailed How Typically organized by department Task Specific Instructions
■ Auditor(s) look for evidence that demonstrates requirements have been met.
The sources of information gathered are grouped into these categories:
– Documents verify relevant, clear and complete procedures, work instructions, guidelines, etc., are readily accessible
– Records: verify appropriate records have been kept to demonstrate that requirements of procedures and the standard have been met
– Observations: verify activities, workplace conditions, controls are in place
– Interviews: verify health and safety system/program understanding.
■ If all available sources of information (minimum 2) are
consistent then the information may be considered evidence of conformity. Inconsistent information is evidence of
nonconformity.
■ Evidence is measured against the audit criteria to determine
conformity or nonconformity
Collecting and Verifying Information:
■ Review Documents and Records
– Note details of documents and records reviewed
■ Observations while at the facility and throughout the audit
– Note relevant observations that demonstrate conformity
and nonconformity
■ Interviews during the facility tour and throughout the audit
– Conduct interviews appropriate to the situation and the person
– Interview people from appropriate levels and functions
– Make notes of evidence of conformity and nonconformity
– Summarize the results of the interview with the person
Collecting and Verifying Information:
■ How much is enough?
– Sufficient to demonstrate a consistent pattern of
conformance
– One piece might be enough, for example:
• maybe only one incident occurred so there will be only
one investigation report
• observed one failure to use confined space procedure;
• only one work instruction
– Perhaps 10 to 50 pieces may be appropriate, for example:
Generating Audit Findings/Conclusions:
■ Evaluate all audit evidence against audit criteria
■ During the audit, evidence must be presented that the criteria are in place for conformity. If any requirement is not met, a nonconformity is noted.
■ Audit findings/conclusions indicate conformity or nonconformity to criteria
Note: Any corrective actions to a nonconformity does not change the audit finding/conclusion.
Conformity
■ Conformity is the fulfillment of the audit criteria which includes requirements of an audit standard, the
workplace’s health and safety policies, practices, procedures and related documentation.
Nonconformity
■ Nonconformity is the non-fulfillment of, or deviation from, the requirements. It is categorized as Major and Minor.
MAJOR nonconformities:
■ the issue will continue to occur because of how the HSMS and health and safety program are structured
■ there is unacceptable risk to a worker’s health or safety
■ there are serious legal implications, or
■ there is an accumulation of related minor nonconformities.
MINOR nonconformities:
■ the HSMS and the health and safety program structures are valid, but there was minor deviation (e.g. human error)
■ there is no unacceptable risk to the worker
■ there are no significant legal implications, and
■
■ The report must reference the requirement (i.e. A.2), and the evidence that supports the findings/conclusions of conformity and nonconformity
■ Indicate any situations encountered that may decrease the
reliability of the audit conclusion
■ Diverging opinions about findings and conclusions should be
discussed, resolved if possible, and recorded if not resolved
■ The report must include the date(s) of the audit, report date, auditor(s) name
■ Auditor(s) prepare to present or discuss the audit with the Owner/Senior Management
■ Owner/Senior Management reviews the audit report
■ Ensure the Owner/Senior Management agrees with and understands the audit conclusions
■ A record of the Owner/Senior Management review
■ Establish a timeframe for the employer’s continual improvement plan
As a result of the audit findings/conclusions:
■ An action plan is developed for all nonconformities
■ The action plan outlines how nonconformities will be corrected, responsibilities assigned and timelines established.
■ The action plan is developed or reviewed, approved,
resourced and initiated by the Owner/Senior
Management.
■ The employer’s auditor(s) may conduct follow-ups to ensure the element is progressing to conformity
■ An action plan can also be used for continual improvement
■ When a criteria requirement is met, but may deteriorate into a nonconformity, the audit may indicate an opportunity to improve.
Continual Improvement
■ The process of enhancing the HSMS to achieve ongoing improvement in overall health and safety performance.
■ Improved performance on its own IS NOT continual improvement, it is an outcome – you must improve the way you manage.
Year-end Report Checklist:
*All Advantage firms submit the following documentation attached to the Checklist;
1 Written Standard 20%
2 Internal Auditor training record 20%
3 Completed an approved HSMS Review (internal audit) w/Senior Management sign-off
acknowledging their involvement 20%
4 Written Continual Improvement plan addressing HSMS Review w/Senior Management
sign-off acknowledging their involvement 20%