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    Safety, Health, and Environment Audits With Selected Case Histories

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    Safety, Health, and Environment Audits With Selected Case Histories

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    Tushar Kanti Jha
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    audit guidelines

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    Environmental audits

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    audit guidelines

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    Safety, Health, and Environment Audits With Selected Case Histories

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    Tushar Kanti Jha
    audit guidelines

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    Loss Prevention Bulletin 241 February 2015 | 7 Safety, Health, and Environment audits with selected case histories Lee Allford and Phillip Carson Summary ‘An audits a structured, proactive management tool to assess systematically compliance with defined standards, legislation, policy, or best practice. Investigation into major accidents in recent years have often revealed shortcomings inthe aut process. This article outlines the audit process, their strengths and weaknesses, and reviews cases where audit outcomes have indicated breaches in standards/legislation or where they have failed to identity problems that eventualy led to incidents Keywords: Audits Background Investigations into major accidents in recent years have revealed flaws in process safety systems and, more specifically shortcomings inthe aualt process itself, which is designed to maintain and improve the system. The irony of flawed audit assurance is not lost on Sutton’ who warns that one of the early signs ofa degraded process safety culture is that of ineffective auditing. This shows itself in the softening of had news to senior managers, afallure to find root causes of deficiencies, and an inadequate follow up to audit findings. Inthe aftermath of Texas City, the BP U.S. Refineries Independent Safety Review Panel (known informally as the Baker Panel) expressed its concern that The principal focus of aualts was with compliance and verifying that required management systems were in place to satisfy legal requirements. it does not appear, however, that BP used the audits to ‘ensure that the management systems were delivering the desired safety performance or to assess a site's performance against industry best practices.* Inone ofits ten key recommendations the Baker Panel made ‘explicit reference to process safety auditing and proposed ‘that BP should establish and implement an effective system to audit process safety performance atts US refineries Ina similar vein, the HSE* found that at Buncefield: auditing and monitoring arrangements focused on whether asystem was in place; the audits did not test the quality ofthe systems and, most importantly, did not check whether they were being used or were effective (© sion of Chemical Engineers 02609574/15/$17.63 + 0.00 Introduction ‘Audits a structured, proactive management tool to assess systematically compliance (preferably by ‘independent qualfied auditors) with defined standards, legislation, policy, and/or best practice. The short-term objective isto identify areas for improvement with the overall aim of reducing the chance of an accident/incident and attendant consequences including ‘death, injury. physical damage, prosecution, financial oss (e.g repairs/reconstructon, re-training, manpower associated with investigations, compensation, tanshed image, businessloss, ec. For amajor hazards operator, process safety audits check that what the business does in realty matches upto both what it says it does in terms of policies and procedures and what it should doin terms of continuous rsk reduction and ensuring that major accident risks are reduced to as low as reasonably practicable. They are mandated in Europe for onshore major hazard establishments by the Seveso directive, Audits ae useful both in confirming areas of conformance and in identifying weaknesses. Scope may include the entre management system as exemplified by Table or focus on specific elements of a process or general plant safety. They should embrace the system from cradle-to-grave and extend over the whole supply chain. Table 1; Selected relevant management systems Management stem [Tie TEO4S00/0RSAS | OccpaionHehand Salty Magee ‘001 Saiem TBO 07 A007 [Enver aagerent Sse "5037000 Fisk Management 15030075001 | Out Manageme Sens 1508011 Gaelines for Ang Management Stes pecrnisiore | Pees le Mangere fH Heros Development ofa Safty and nvtonnera ‘Api Recommended Ss Maragier ogo foe Open nd ocr Pees sf Recormened Paice were _—_| agen Rtg ees Mn Audits comprise: ‘First party audits conducted by operational staff from within the unit being audited, + Second party audits conducted by staf from within the ‘company but external to the unt/site being aucited (e.g, Head Office). IChemE 8 | Loss Prevention Bullen 241 February 2015 + Third party audits conducted by auditors external to the company (e.g. consultants, regulatory authorities) Pros and cons of each type of audit are highlighted elsewhere” and arguably the level of bias will reduce in going from first to third party audits. The audit process ‘Audits are usually initiated by correspondence from the auditor to senior plant management when audit scope, schedule and audit team composition are clarified The audit visit Auditors conduct both assessment and verification simultaneously by gathering evidence principally through interview of staf, inspection of plant, examination of documents and observation of activities. Itis important that auditors select a representative sample of activities and ‘operations that offers an authentic picture ofthe management ‘of major hazards across the site. Some ways of gathering auelt ‘evidence will provide greater insights than others but all used in combination will help to corroborate and suppor the final audit opinion. A challenge for auditors isthe organisation of ‘access to audit evidence such as key personnel an night shift, and plant and equipment that arein use. ‘Scoring an audit provides a meaningful way to feedback to the audited party and help focus site attention on the most important and urgent areas for fllow up action. For a process safety audit the focus will be on safety critical equipment and systems designed to control e.g, major hazard rsks and ‘equally, the presence of management systems and culture which detect warning signs of failure. Post audit Often the auait team leader compiles the audit report which may be in draft form by the time ofthe closing meeting, ‘or completed shortly after the audit. Many organisations ‘offer some time for the site to respond tothe findings and recommendations presented in the draft audit report. Audit ‘teams must retain their working papers and copies of relevant raw data from the audit in order to support the findings of the final epor. ‘The mast challenging aspects of auditing tend to be the ‘tracking, validation and close-out of audit actions. Itis the task ‘of the audited site to take responsiblity for the completion of audit actions and not that ofthe audit team, Again, it is vital ‘that senior managers commit the resources to deal with those actions that require funding and investment. ‘As the internal auditing programme matures, the programme should be subject to regular review and improvement based on: + debriefing of auditing teams + feedback from audited sites; + benchmarking of audit processes with peer companies; and ultimately + process safety performance across the site and wider business. Audit strengths and weaknesses ‘Maximising the quality and impact of audits requires: IChemE + Well-trained, experienced, independent, objective, down- to-earth, honest auditors. Aualtors need to possess a range of skills from aualting skill including note taking, sampling and interviewing, active listening and presenting) as well asthe technical knowledge and experience of plant and process safety and specific technologies. Since all the specialist skills required for a process safety audit are rarely found ina single individual, team approach is often required + Enlightened senior management viewing audits as more ‘than compliance but keen to establish how systems can be further improved, and fostering mature relationship ‘with auditors. Commitment to the audit from senior ‘management is crucial inthe context that an internal auditing programme requires resources in order to build team which is competent to conduct audits and whose judgement will be taken seriously across the business. + Adetailed and focused audit plan issued well in advance ofthe audit (possibly including a pre-audit questionnaire or site familarisation visit). Aucit intervals tend to be risk- based and can be a function of several factors including the nature ofthe inherent hazards present on asite, age profile of plant, incident track record, most recent audit score achieved, intensity of external regulatory scrutiny + Auditor familar with results of previous site audit findings. + Adequate prior preparation by aucitee, including internal audit prior to an external audit ‘+ Site staff well-trained in the safety management system, + Sound documentation (procedures, protocols, SOPS) on the system, controls, training records, maintenance records, etc. + An on-site opening meeting between auditors and senior ‘management (and key staff) n order for the audit team to communicate the scape and objectives of the audit + Well-planned exit interview by auditors with appropriate management in attendance to ensure that no major surprises are presented inthe final audit report. ‘+ Professional audit report providing prioritised recommendations/guidance (not detailed solutions) with a proposed time plan. ‘+ Formal response by management tothe auditor's report, including an action plan for addressing agreed non- conformances and other observations. + Monitoring of progress of remedial actions against the plan, Clearly, reasons for poor audit ie. failing to identify key areas for improvement, o failure to delver desired outcomes, are varied and include the following: + Auditing for audit sake rather than need, resiting in waste of valuable resources and stretching audit credibly + Inadequate commitment of ste management (audit not given appropriate level of seriousness, ault schedule Constantly modified, lack of resources/ prior preparation, key staff members unavailable during the audt, poor attitude towards auton) + Lack of sil/experience of auditor. + Poor preparation by auditor(s)/inadequate aust plan wth no clear objectives. © tsiion of Chemical Engineers (0260.9574/13/$17.53 + 0.00 + Defensive attitude of auditee + Attempts to blame individuals for shortcomings + Attempts of audiee to influence auditor (diversions, time wasting). + Falure of auditeeto respond to requests in atimely + Poor aueit traling/document qualty + Absence of senior management at ext interview. + Audit repor of poor quality (poor construction, ambiguity, errors failure to prortise findings with stretching but realistic actions/recommendations/timeframes, lack of executive summary highlighting the more serious shortcomings for senior management) + Senior management response to auditor's report tone, timeliness, commitment). + Inadequate monitoring of agreed action plan by management with no progress reports to aueltor against milestones. ‘Audit findings should also be reviewed holistically and ‘compared to previous reports to identify trends and major management flaws. The audit programme itself must have its ‘own policy and guidelines/SOPs and an independent quality assurance audit ofthe audit function should be periodically undertaken.*” The effectiveness of the audit programme needs to be regularly reviewed at a senior level with a view to continuously improving its operation. Warning bells need to be sounded should the audit programme remain unchanging and static and delivers only good news to senior managers. Selected case histories Itis impossible to prove either that a good audit prevented ‘an accident/incident, or that a bad audit resulted in one. Nevertheless, the following case histories illustrate that audit ‘outcomes can indicate breaches in standards/legislation that are otherwise likely to have increased the chances of mishap/ prosecution unless rectified, or that audits failed to identify problems that eventually led to untoward events. As the safety ‘management system matures audit findings should reduce in severity Case 18° Inthe oil and gas industry, technical, operational and ‘organisational elements which are intended individually or collectively to reduce the possibilty fora specific error, hazard ‘or accident to occur, or which limit its harm/dlisadvantages are termed "Barriers’. Examples include those which prevent leaks or ignition, reduce fire loads, ensure acceptable evacuation, land prevent hearing damage. Non-conformances identified

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