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Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008

Page 1 of 34
Revision: 02 Revision Date: October 2016

PSM 10- AUDIT & OBSRVATION


Scope:
This Document describes the requirement for complying with the Process Safety
Management element on Audits & Observations.

Authorizations:

Reviewed By: ________________________


Farrukh Iqbal Qureshi
Prepared By: ____________________________ Corp. HSE Manager
Ammar Hussain
HSE Engineer
Reviewed By: ________________________
Rizwan Ahmed Taqi
Chairman Sub-HSE (PSRM)
Reviewed By: ____________________________
Syed Muhammad Farooq Ahmed
Safety Advisor Approved By: ________________________
Jahangir Waheed
VP Manufacturing

Change Record:
All changes have been made Bold, Italic and Highlighted in Grey

Sr. Date Rev. Page Section Change Description


No. No. No.
PSRM 14 – Auditing and PSM 12 – Effective Audits have
1 Oct ‘16 02 All All
been merged into PSM 10 – Audits & Observations

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

SECTION-1 TABLE OF CONTENTS


SECTION-1 TABLE OF CONTENTS ..................................................................................................................... 2
SECTION-2 BASIS ................................................................................................................................................. 3
2.1 PURPOSE ........................................................................................................................................................................................... 3
2.2 SUMMARY ......................................................................................................................................................................................... 3
SECTION-3 DEFINATIONS & ABBREVIATIONS ............................................................................................... 4
SECTION-4 PERSONNEL SAFETY AUDITS......................................................................................................... 7
SECTION-5 PERSONNEL AUDIT PROGRAM ..................................................................................................... 8
5.1 SAFETY CONTACT AUDIT ................................................................................................................................................................. 9
5.2 MANAGEMENT SAFETY AUDITS ...................................................................................................................................................... 9
5.3 QUALITY ......................................................................................................................................................................................... 10
5.4 FREQUENCY .................................................................................................................................................................................... 10
5.5 RESULTS.......................................................................................................................................................................................... 10
SECTION-6 GUIDE TO CONTACT SAFETY AUDIT .......................................................................................... 12
6.1 INTRODUCTION.............................................................................................................................................................................. 13
6.2 AUDIT ............................................................................................................................................................................................. 13
6.3 REACT ............................................................................................................................................................................................. 14
6.4 COMMUNICATE ............................................................................................................................................................................. 15
6.5 FOLLOW-UP ................................................................................................................................................................................... 15
6.6 RAISE STANDARDS ........................................................................................................................................................................ 15
SECTION-7 BASIC AUDIT PRNCIPLE & TECHNIQUE ..................................................................................... 16
SECTION-8 TRAINING METHODS & OBSERVATIONS TECHNIQUES ......................................................... 17
SECTION-9 AUDIT SCHEDULE PHILOSOPHY ................................................................................................. 19
SECTION-10 SAMPLE MSA SCHEDULE MATRIX .............................................................................................. 20
SECTION-11 MSA OBSERVATION CATEGORIZATION .................................................................................... 21
SECTION-12 MSA QUALITY CRITERIA .............................................................................................................. 22
SECTION-13 PSM INTERNAL AUDITS ............................................................................................................... 23
13.1 AUDITS PLANNING ........................................................................................................................................................................ 23
13.2 PSM 1ST PARTY AUDITS ............................................................................................................................................................... 23
13.3 PSM 2ND PARTY AUDIT ................................................................................................................................................................ 24
13.4 AUDIT REPORT ............................................................................................................................................................................... 26
13.5 RECOMMENDATIONS .................................................................................................................................................................... 26
SECTION-14 PSM EXTERNAL AUDITS ............................................................................................................... 27
SECTION-15 AREA AUDITS ................................................................................................................................. 27
SECTION-16 HAZARDOUS SUBSTANCES SURVEY .......................................................................................... 28
16.1 OBJECTIVE ...................................................................................................................................................................................... 29
16.2 HAZARDOUS SUBSTANCES BASIS AND GUIDELINES.................................................................................................................. 29
16.3 HAZARDOUS SUBSTANCE / CHEMICALS ..................................................................................................................................... 29
16.4 HAZARDOUS SUBSTANCES SURVEY METHODOLOGY ............................................................................................................... 30
16.5 HAZARDOUS SUBSTANCE SURVEY REPORT................................................................................................................................ 31
16.6 RECOMMENDATIONS .................................................................................................................................................................... 31
SECTION-17 SAFETY CRITICAL SYSTEM AUDIT............................................................................................... 33
17.1 TEAM NOMINATION AND PREPARATION ................................................................................................................................... 33
17.2 AUDIT PROCEDURE ....................................................................................................................................................................... 33
17.3 DEFICIENCIES AND REPORT WRITING ......................................................................................................................................... 33

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

SECTION-2 BASIS
2.1 Purpose
The purpose of this document is to discuss importance of effective auditing in site safety
management and provide guidelines for conducting and evaluating safety audits.

EPCL believes that audits are important tools in the establishment, measurement,
Maintenance and continuous improvement of process safety performance. Audits compare
Performance vs. established standards and evaluate effectiveness of systems in
accomplishing their intended purpose. Proper auditing provides a process that nourishes
and reinforces correct systems, behavior and work practices while identifying opportunities
for improvement.

2.2 Summary
Auditing is an important aspect of safety management. Used properly and tactfully, audits
bring various good results, e.g.
 Maintain standards by ensuring that everyone follows the rules and procedures.
 Highlights areas where rules and procedures are insufficient.
 Measures the effect of safety training and reveals weaknesses.
 Motivates supervisors/ workers by giving results of their safety efforts.

A documented audit program should be in place which also provides guidelines for
conducting and evaluating results of safety audits by line managers and safety personnel.
Necessary training should be provided to all relevant personnel on auditing techniques.

Audit program/ results should be stewarded by line managers/ MHSE. The audits should be
used to determine necessary changes in management of safety. This procedure covers the
requirements, guidelines on how to conduct audits, compile report and steward
recommendations for following types of audits: 1st Party PSM Audits (Internal Audit); 2nd
Party PSM Audits; 3rd Party Audit (External PSM Audits); Hazardous Substances Survey; Safety
Critical System Audit.

The intent is to comply with the requirements of OSHA regulation 29 CFR 1910.119 and EPA
regulation 40 CFR Part 68.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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SECTION-3 DEFINATIONS & ABBREVIATIONS

3.1 Audit

An audit is a methodical examination of a facility’s procedures and practices to verify


whether they comply with Corporate and legal requirements, internal policies and good
practices, whether they are being followed and whether they are effective.

3.2 Audit Types-1st Party Audit


An audit of a site carried out by team comprising of personnel working at that site, as per
site’s established HSE program. It is an Own-Area Audit in which no independent auditor
(from outside the company) is employed. There are several types, or levels, of 1st party
audits typically conducted at a site, some types are listed below

Behavioral Based Audit:


An employee(s) observes others performing work and provided feedback. Behavioral based
audits vary in their degree of structured approach.

Layered or Tiered Audit:


A manager leads the audit and has one employee who directly reports to the manager as an
audit team member. The strength of layered or tiered audits is that they allow the manager
to demonstrate the value of HSE program to their subordinates. These are most effective in
an area where the management member has responsibility.

Area Audit:
The auditor or audit team focuses on the condition of a geographic area within the site. The
strength of area audits is that all areas of the site can be covered in one to three months.

Cross Functional Audit:


Members of management audit areas outside of their area of responsibility. The strength of
the cross area audit is that an auditor with a different perspective evaluates an area and
learns how another area of the site addresses HSE challenges.

Focused Audits:
A focused audit concentrates on a single aspect of a HSE management system e.g. single
element of PSM program. The bulk of the audit period is devoted to this focused subject.
e.g. audits of LOTO, confined space, work permits etc.

3.3 Audit Types-2nd Party Audit


An audit of a site carried out by independent auditors, as per site’s established HSE program.
The auditors are employees of the same company and thus are knowledgeable in corporate
HSE program; however, they are working at different sites / sister-companies. The strength
of 2nd party audit is that auditors are external to the site and therefore, carry out the audit

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

from an independent viewpoint, which can help in identifying area of improvement that may
be overlooked during internal audits.

3.4 Audit Types-3rd Party Audit


An audits of site PSM program conducted by personnel who are external to Engro Corp; e.g.
DuPont, Government agencies.

3.5 Audit Team Leader


An individual who leads an audit and meets the mandatory qualifications and training
requirements of this PSM standard.

3.6 Consequence analysis


The development of potential scenarios describing hazardous events that may occur due to
loss of engineering or administrative, controls and the evaluation of resulting impact on site
personnel, off-site communities, and the environment. Consequences are analyzed
independently of the event's probability or frequency of occurrence.

3.7 Hazard
An inherent property or characteristic of a material, system or process, that has the potential
for causing serious injury to people and/or property or environmental damage.

3.8 Hazard and Operability Analysis (HAZOP)


A systematic, qualitative technique to identify process hazards and potential operating
problems using a series of guide words to study deviations of relevant process parameters.

3.9 Management of Change (MOC)


A systematic procedure, change of design, or test authorization procedure for the
analytical review of changes (including subtle changes) to the documented Process Safety
Information (PSI) package and/or facilities for consideration of potential hazards being
introduced to the process, system or operation, and their elimination or control.

3.10 Operating Procedures


A comprehensive set of instructions for the operation of a process. They should provide a
clear understanding of the detailed operating parameters and limits for safe operation in all
process modes (e.g., start-ups, normal operation, shutdowns), including an explanation of
the consequence of operation outside the process limits and a description of steps to be
taken to correct and / or avoid deviations.

3.11 Process Design Basis


Description of the process including process chemistry, material and energy balances,
process steps, process parameters for each step, limits for each parameter (maximum,

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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minimum, preferred) and the consequences of deviation (i.e., above maximum condition or
below minimum condition).

3.12 Process Hazard Analysis


A PHA is a systematic and comprehensive study of the hazardous events that could occur in
the process, using a multi-disciplined team and a combination of methodologies. The team
evaluates the possible harmful effects of each event versus the current protection and
decides on whether additional protection is needed. Recommendations are made where
appropriate. Follow up on recommendations is required.

3.13 Process Hazards Review (PHR)


The application of process hazards review methodologies (also commonly referred to as
hazard evaluation methodologies) to determine the significance of hazardous situations
associated with a process or activity. It uses qualitative or quantitative techniques to pinpoint
weaknesses in design, operation and lines of defense, provided by engineering and
administrative controls, which can lead to hazardous events. It may also provide an
assessment or risk resulting from the magnitude of the consequence and the probability of
the event occurring. In general, the application of a hazards evaluation methodology to an
area under study.

3.14 Process Safety Management (PSM)


Application of management systems and controls (programs, procedures, audits,
evaluations) to a manufacturing or chemical process in a way that process hazards are
identified, understood and controlled so that process related injuries and incidents (which
might affect plant personnel, contractors or off-site communities) are prevented.

3.15 Recommendations
Proposed modifications to equipment, facilities, operating procedures, engineering controls,
or administrative controls deemed necessary by a process hazards analysis study team or
audit team to reduce risk and permit safe operation.

3.16 Risk
The product of the expected frequency (events/unit time) and the consequences
(effects/event) of a single hazardous event or group of hazardous events. Typically it is used
as a measure of potential economic loss or human injury in terms of the probability of the
loss or injury occurring and the magnitude of the loss or injury if it occurs.

3.17 Site
The entire area within a geographical boundary, which houses one or more facilities, under
the jurisdiction of a common management structure.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

3.18 Standard
A set of either mandatory requirements or optional guidelines based upon corporate policy,
Government regulations, or consensus industry experience / practice.

3.19 Abbreviations

EPCL Engro Polymer Chemical Limited PHR Process Hazard Review

EPA Environmental Protection Agency PPE Personal Protective Equipment


HSE Health, Safety and Environment PSI Process Safety Information

PSM Process Safety Management MSA Management Safety Audit


MOC Management of Change QSP Quality System Procedure

PFDs Process Flow Diagrams PHA Process Hazards Analysis

SECTION-4 PERSONNEL SAFETY AUDITS

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Auditing is an important aspect of safety management as it allows management to monitor;


1. How the safety program is progressing.
2. Conditions as they exist at the site, including production, maintenance, laboratory, office,
warehouse and other areas.
3. Observe unsafe acts or conditions in the workplace.
4. Observe workers during their normal workday.
In addition, audits
1. Provide lower levels of management and workers a visible indication of management’s
commitment to safety.
2. Improve housekeeping and safety standards.
3. Provide the opportunity for management to communicate with employees about safety.
4. Increase safety awareness.

Safety auditing involves sampling the site’s safety program as a whole; it is not an in-depth
inspection of every aspect of the program. The safety management auditor should be
looking at the broad spectrum of safety programs to see if they are effective, if they are
being followed, and, ultimately, if they are getting results. Part of a safety audit is what is
usually called a safety inspection but with the major emphasis on observing people working
at their normal jobs; particular attention is paid every now and then to special situations.

Increase of safety awareness is the most important result of regular auditing since unsafe
actions result from a lack of safety awareness. A procedure cannot be provided to cover all
the actions of workers; therefore, we must rely on increasing their safety awareness which
would result in reducing the unsafe acts.

SECTION-5 PERSONNEL AUDIT PROGRAM


Site would have two types of Management Safety audits on regular frequency.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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5.1 Safety Contact Audit


Safety Contact audits approach is considered as one of the best audit techniques. During a
one-on-one audit, a manager and a subordinate audit a portion of the subordinate’s area
together. This procedure continues down through the line organization until all members of
management up to a specific Tier Level are involved in safety audits. This procedure ensures
management visibility & commitment to safety. As the program progresses, first-line
supervisors and team leaders (often accompanied by an employee or team member) make
daily audits of their areas discussing with employees any deviations from the standards. As a
result deficiencies in the workplace will decrease and safety performance will improve.

When conducting audits, managers must do more than simply observe employees,
equipment, and the work environment. A good safety management auditor talks safety with
employees during the audit. These conversations can help the auditor answer questions such
as:

1. What is the frequency of employees attending safety meetings?


2. What do employees think of safety meetings?
3. Are employees receiving the communications that are passed down the line?
4. What are the safety problems that employees face on their jobs?
5. What do employees think about the increased emphasis on safety?
6. What are the quality and quantity of the initial training given to new employees and the
continued training given to experienced employees?
7. Are employees’ concerns addressed within a reasonable time?
8. Do employees or contractors have say in the overall safety program within their work
group?

When audit results reveal gaps that require the authorization of other area resources, these
resources must be requested without delay. Simply requesting the resources to solve a
problem, however, does not relieve the manager of responsibility for operating a safe
workplace. If necessary, equipment must be shut down or the area roped off or barricaded
until the problem is actually resolved.

5.2 Management Safety Audits


All Executives should formally visit, tour, and audit the site as per defined monthly MSA plan
circulated by HSE Department. The visit should be planned well in advance and should not
be postponed or canceled except for an extreme emergency, and even then it should be
postponed for only a day or two at the most. During this visit, the auditor should review the
site’s safety program, activities, and progress. While at the site, the auditor should spend at
least 30 minutes and meeting at least 03 employees and observing work habits and
conditions. At the end of the visit, the auditor should give a brief review of the observations

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

made during the day and his impressions of the site. A formal audit report shall be
submitted to HSE department via online MSA application. Focus of the audit should be to
establish a safety contact with down the line employees. Additionally, all observations made
should be concurred with the respective interface before filing a formal MSA report.

5.3 Quality
A Manager should ensure that the audits conducted in his area are:
1. Effective
2. Of a consistent standard
To ensure the quality they should frequently match the results with his observations. This
comparison will show the Manager whether the line supervisors need further training in
conducting audits and what else you need to do to ensure a common standard of auditing
throughout the department or facility.

5.4 Frequency
1. VP Manufacturing and GM Operations should audit at least 30 minutes on once a month
of assigned areas as per MSA schedule issued by HSE.
2. Departmental Managers, Unit Manager/ Section Heads should also audit their areas for
at least 30 minutes twice a month of assigned areas as per MSA schedule issued by HSE.
3. Senior Engineer till E-2 (except Production Individuals) should also audit their areas for at
least 30 minutes twice a month of assigned areas as per MSA schedule issued by HSE.
4. All production Site Coordinator/ Shift In charge/ Shift Supervisors should audit their areas
weekly and formally record observations on online MSA application

5.5 Results
A site wide or area-wide auditing program results should be analyzed to observe trends in
safety performance.

To enable to see site wide or area-wide trends and problems, two basic conditions must be
met:

1. All MSA observations to be concurred with respective interfaces


2. All MSA auditors to submit their formal report on online MSA Application
3. All MSA observation marked should be closed out as soon as possible by responsible
interface
4. Audit results are tabulated on monthly Basis by HSE
5. Audit results are analyzed on Quarterly Basis by respective department in Sub HSE B & A

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Each point on the graph is determined by the total number of audit defects recorded during
the month, divided by the number of man-hours spent auditing that month. For instance,
two people auditing for three hours is equivalent to one person auditing for six hours.

The site wide audit trend should be comparison of the area audits & the audits by Safety
Department in a given period. Different category can be plotted.

Such plotting helps to measure effectiveness at improving any particular aspect of safety
which can be decided is important site wide or in given areas. Breaking down the overall
audit results into categories can also show you where you need to focus your attention.

5.5.1 Quantifying Results


There are two types of methods used for quantifying the results.

5.5.1.i The Time-Weighted Index

TWI = No. Unsafe Situations____ x 100


Total time spent auditing

This sort of index works well in operations that are not labor intensive, like Process Plants,
where you might not see many workers when you audit. There, you will be looking for
indications of unsafe acts that occurred before you got there; for example, a forklift sitting
idle with its forks raised.

5.5.1.ii The Unsafe Acts Index


If you have a location that is labor intensive like PM&S, you might prefer to use an unsafe
acts index.

UAI = No. unsafe acts x 100


No. people observed working

These ways of recording audit results provide a quantitative means of presenting


information.

5.5.2 Results you can expect


1. Many observations in a new program.
2. Rising trends as auditors become more adept. It will look as if your safety performance is
getting worse instead of better. You should be prepared for this occurrence.
3. Lowering trends as employees react with safer work habits.

If the frequency of unsafe acts rises again, it may be symptomatic of an underlying problem
you need to tackle. A strategy for tackling problems could include:
1. Publicity.
2. Safety discussions.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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3. Close Monitoring.
4. New procedures.
You can use any or all of these methods. The Important point is that you cover all
employees.

5.5.3 Using Results


To make full use of audit results to see where you should direct your efforts, you should also
review audit reports submitted by supervisors in your line organization to recognize such
factors as:
1. A work area with a high infraction rate.
2. Supervisors who are not conducting effective audits.
3. Safety violations that occur throughout the site or area.
4. Recurring safety violations.
5. A rise in the number of violations.

After spotting any of these factors, you can take actions where appropriate (such as a
reviewing auditing technique or advice supervisors of the need for action (as in the case of
safety emphasis for an area with many audit defects).

SECTION-6 GUIDE TO CONTACT SAFETY AUDIT

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-II / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

6.1 Introduction
One-on-one safety contact audit is an essential feature of the Management audit program. It
is a formally scheduled audit conducted by auditors. The specific objective being that one-
on-one contact is established between supervisory level & employees to focus on safety.
These audits are to be conducted by all level of management employees from Plant VP
Manufacturing to Shift In charge.

Safety and housekeeping in your area reflect the standards you are willing to accept; they
will improve as soon as you communicate convincingly that you want them to improve. The
intent of this guide is to help you improve safety and housekeeping by establishing a
personal safety audit system.

This guide has five steps:


1. Audit.
2. React.
3. Communicate.
4. Follow-up.
5. Raise standards.

6.2 Audit
You must get out into your area(s) of responsibility every week with one of your direct
subordinates to make a safety audit. You do not have to devote a lot of time to the audit,
and you do not have to conduct a complete tour of an area. If you have several locations
that you know are trouble spots, concentrate on them first. Sample one or more portions of
an area where you can audit employee work practices and conditions quickly and effectively.
Conduct an audit at least once a week, spending 30 minutes and make at least 03 contacts. It
is crucial that you do not try to combine a safety audit with other visits to the area. Your
safety audit to an area must be specifically designed to evaluate safety. Learn to take notes
of the things you see.

The audit process to be followed would be:

6.2.1 Become Familiar with Safety Requirements


Prior to auditing the areas, review the area, equipment, and hazardous chemical safety rules;
process hazards; and emergency procedures. Wear the proper protective equipment, just as
if you were doing the job.

6.2.2 Focus on People


Make sure each audit involves the observation of and communication with people in the
workplace. More focus on unsafe acts than conditions. When someone is working unsafely,
follow these steps:
1. Observe; then get the person’s attention.
2. Comment on what the employee was doing safely.
3. Discuss with employee:

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 The possible consequence of the unsafe act.


 Safer ways to do the job.
4. Get the employee’s agreement to work safely in the future.
5. Discuss the safety issues of the job.
6. Thank the employee.

6.2.3 Ask Open-Ended Questions


Gain a better understanding by asking open-ended questions—ones that cannot be
answered with a simple “yes” or “no.” Such questions not only aid in an accurate evaluation,
they frequently stimulate the thinking of others as well.

6.2.4 Take Notes at Appropriate and Timely Opportunities


Historical safety contacts between supervisors and subordinates have been negative. Thus,
do not walk around with a clipboard or notebook in your hand. The first impression people
will have is that you are out to take names and report. Make your observations and, at an
appropriate time (often just after your contact with the employee), jot down a few notes to
jog your memory when you make up your audit report following the audit. Remember; do
not rely on your memory. It is difficult for most people to remember more than a handful of
observations, and erroneous reporting can only weaken the impact of the audits. Therefore,
it is important that you take notes on a periodic basis during your audit.

6.2.5 Respect Lines of Communication


As a matter of courtesy, keep members of supervision who are responsible for the audited
area informed of your findings. Whenever possible, channel all recommendations and
remarks through the line organization.

6.2.6 Draw Conclusions


Draw meaningful conclusions from your observations. In many cases, the greatest value of
an audit lies not in the correction of specific deficiencies but in the conclusions upon which
measures to prevent recurrences can be developed. You should be careful to avoid drawing
sweeping conclusions where the evidence is not sufficiently strong to support them and
avoid overgeneralizations. In these cases, suggesting possible conclusions may be more
useful because the question will remain open to further investigation.
6.3 React
The only way you and your site can benefit from your audit is for you to react. The manner
in which you react may well be the strongest single element in improving the safety climate
at your site. Your reaction (or lack of it) tells your organization what is and is not acceptable.
With the philosophy that all injuries and occupational illnesses can be prevented, you must
display confidence that your site can achieve high standards of safety.

Specifically, each time you audit an area, building, work site, room, or other facility, you must
ask yourself a question and make a decision: “Are all aspects of safety acceptable?”
Whenever the answer is “no,” you should record your reaction and comments about how the
facility deviates from your standards. Your standards will not be static; they will change with
time and as you develop more skill in auditing.

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You must come away from each audit with a reaction:


1. The operation is acceptable because . . . .
2. The operation is not acceptable because . . . .
3. The operation has deteriorated because . . . .
4. The operation has improved because . . . .
6.4 Communicate
Since you have already accepted the basic principle that safety is a line organization
responsibility, the next step in your personal safety audit effort is to communicate your
reaction. Talk with your subordinate who has responsibility for the area you audited. Stick
to the line structure, and do not be casual about this communication.

In order for the contact to be productive, your subordinate must understand that:
1. You audited his area.
2. You are pleased (or displeased) with what you saw because of. . . . (Discuss your
observations.)
3. You expect him to react to your comments, and more importantly, to improve the quality
and effectiveness of his own audit system so that permanent improvements are made.
4. You will audit the area again in a specified number of days.

You and your subordinate must understand the implications of these points. If you expect
your subordinate to address certain situations, be sure he has the necessary authority to
obtain the resources to appropriately react to your comments.
6.5 Follow-up
Follow-up is the magic step for achieving results. You have now spent time auditing,
reacting, and communicating. If you fail to set up an effective reminder or tickler system to
enable you to follow up personally and demonstrate that you mean what you say; your
efforts may be wasted. Failure to follow up will give your subordinates the perception that
you do not care and those high standards of safety are not one of your important priorities

You must clearly communicate your assessment of the obtained results to your subordinates.
By doing this in an effective, timely manner, you will help them learn to manage safety more
effectively in their area of responsibility.

6.6 Raise Standards


By consistently following the first four steps, you will see steady improvements in safety and
housekeeping at your site. Part of the challenge will be to keep raising your standards and
providing the leadership necessary to continue to make progress. First, solve the gross
problems, and then begin to fine-tune your safety and housekeeping efforts.

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SECTION-7 BASIC AUDIT PRNCIPLE & TECHNIQUE

1. Make a commitment to spend a predetermined amount of time for auditing. While


auditing does not require a great amount of time, it does require a regular commitment
of time.
2. Sample conditions in one or more small areas rather than attempt to complete an entire
area tour. By varying the location of audits, supervisors can cover their entire area of
responsibility on a regular basis.
3. React appropriately during audits to set the safety climate in their areas. Never let a
safety violation pass without taking immediate corrective action. This reaction, or a failure
to react, tells all subordinates what a supervisor finds unacceptable-and acceptable.
4. Build pressure. Supervisors should show what they expect by their reactions during their
first audits. They can then use subsequent audits to build pressure for improvement. As
their groups meet one set of goals, supervisors can increase the pressure for improved
work habits.
5. List observations. To maintain an effective auditing program, each auditor must make a
formal list of all observations. (See the Attachment-1). He can then use these lists in
discussing audit results with his group and establishing a follow-up system.
6. Follow Up. Each auditor should maintain a “Follow-up” file and follow up on audit items
personally. This personal involvement is a vital step in establishing standards. Employees
will not usually be motivated enough to correct unsafe practices or conditions unless
they know that their supervisor will be back to check. Personal follow-up maintains the
positive pressure of the auditing program.
7. Vary the approach. Supervisors should generally tell employees when their work
practices are being observed. They can then discuss together the nature of the jobs and
any hazards they include.

To get a realistic sample of work practices, however, supervisors can occasionally


1. Make unannounced audits.
2. Enter work areas by different routes.
3. Make observations before announcing their presence.

Precede an announced audit with an unannounced one.

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SECTION-8 TRAINING METHODS & OBSERVATIONS


TECHNIQUES

8.1 Training Methods


For training of line supervisors in the auditing techniques, here are some methods you can
use:

1. Take line supervisors on audits with you.


2. Accompany them on their audits.
3. Discuss your observations.
4. Discuss what the supervisor can do about the safety infractions you have observed
together.
5. Show supervisors how to keep a record of their observations for their own use, plotting
incidents that recur.

8.2 Observations Techniques


On an audit some critical aspect need to be observed. Be aware of safety violations in the
following categories:

1. The positions and actions of people


2. Personal protective equipment
3. Tools and equipment
4. Procedures
5. Orderliness

Here are some specific questions you can ask about each category.

8.2.1 Positions and Actions of People

1. Is anyone in danger of injuring himself by pulling or lifting heavy objects?


2. Is anyone in a position where he or she could fall, be trapped, collide with anything, or be
hit?

8.2.2 Personal Protective Equipment

1. Are employees using the required protective equipment? Does it provide adequate
protection against employees’ exposure to harmful substances?
2. Are they using the equipment properly?
3. If not, why not? Is it inconvenient to get out or hampering?

8.2.3 Tools and Equipment


1. Are the tools right for the job?
2. Are they being used properly?
3. Are they in safe condition?
4. Are homemade tools (not properly designed) being used?

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8.2.4 Procedures
1. Are they adequate? Do they prevent all unnecessary risks?
2. Are they followed?

8.2.5 Orderliness
1. Is the workplace neat?
2. Are things put away properly?

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SECTION-9 AUDIT SCHEDULE PHILOSOPHY

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SECTION-10 SAMPLE MSA SCHEDULE MATRIX

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SECTION-11 MSA OBSERVATION CATEGORIZATION

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SECTION-12 MSA QUALITY CRITERIA

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SECTION-13 PSM INTERNAL AUDITS

13.1 Audits Planning


1. The Manufacturing HSE chairman and HSE Manager are responsible for conducting
appropriate internal / external audits of PSM systems and their implementation.
2. Internal audits of the PSM programs and their status in each area should be completed at
least once every three years.
3. This can be accomplished by conducting audit of a few PSM elements every year and
completing all the 14 elements in three years.
4. As an alternate, audit of all the elements may be conducted in a single year. The audit
program would be reviewed in relevant Sub HSE and authorized by the Manufacturing
HSE. It will be part of the site’s three yearly HSEQ audit matrix.
5. Where a PSM Element(s) is not applicable to a specific Audit Area, this should be
documented properly and stewarded accordingly.
6. The elements of PSM will be divided into different groups with audit team assigned for
each element or group of elements.
7. In order to achieve good quality audit, plant may be divided into different audit areas.

13.2 PSM 1st Party Audits


1st party audits are carried out by line management in their own units to highlight areas of
improvement in HSE. The benefits of a robust 1st party audit include but are not limited to
 A mechanism to gauge both the strengths and opportunities for improvement of the
facility’s HSE managements systems, thereby reducing the facility’s risk of
noncompliance with applicable local regulatory and corporate standards.
 Improvement of skills, knowledge and capabilities of the line organization that deals
with HSE management systems.
 A mechanism to improve the HSE behaviors of an organization by reinforcing
behaviors that are in line with the corporate commitment and providing constructive
feedback on behaviors that are not.

13.2.1 1st Party Audits Matrix


1. Each area in-charge shall develop and maintain 1st party audit matrix for its own area and
follow up.
2. Audits should be scheduled in a manner that avoids predictable audit frequencies (i.e. at
same time and day of the week). Consideration should be given to scheduling some of the
audits during the off-shift and weekends.
3. Audits should be more focused on those elements that are directly applicable to the
respective area.
4. The audit plan should be stewarded by Manufacturing HSE on regular basis.

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13.2.2 Audits Basis


1. The basis for the audits would be a set of questions, including scoring criteria, which will
be maintained and provided to the audit teams and plant management by the Safety
Advisor.
2. The questions will normally be from the “PSM System”.
3. The audit questions will be periodically updated by Safety Section and reviewed by the
relevant Sub-HSE committee or Manufacturing HSE.
4. The audit questions for each PSM should be available as Level-3 document with the Safety
Section.

13.3 PSM 2nd Party Audit


The purpose of 2nd party audits is to determine whether appropriate management systems
and controls are in place to effect compliance with site PSM standards. Second party audit
help to;
• Ensure that site tracks emissions, injuries, illnesses and incidents; keeps data up-to date;
demonstrates historically downward trends.
• Identify emerging issues and establish priorities for HSE stewardship efforts
• Assess the quality of first-party audits.

13.3.1 Criteria for Nomination of 2nd Party PSM Audit Team


Manufacturing HSE shall consider the resources available at the site along with expertise
available at Head Office, EFFERT, Zarkhez Plant, EFoods or other sister companies for the
formation of 2nd party audit team. The audit team should be nominated based on the
following criteria.

13.3.2 Team Leader


1. The audit team leader should have attended a two-day course on the principles and
essential features of PSM.
2. Should have participated in at least two audits as a member of the audit team.
3. Should have an understanding of PSM elements being audited and successful systems
utilized to comply with those elements.
4. Minimum of three years of site operating, maintenance, technical or safety experience.

13.3.3 Team Members


1. The team must include personnel who are knowledgeable in the PSMs and auditing process and
may include membership from Manufacturing HSE. It should also have representation from
Safety Section.
2. Experts in specific disciplines not represented on the team can be called if required.
3. A few new members can be included in the team for training purposes.
4. A typical PSM audit team would have around 06 members.

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13.3.4 Training
The team leader should brief the team on audit protocol and minimum requirements for the
audit. Moreover, Safety Section resources can be used for training purposes. Adequate
preparations must be done to ensure a high quality audit. Team members should receive
overview training using the Audit Checklists.

13.3.5 2nd Party Audit Procedure


1. The PSM element audit team will review the “Answers” assess the site’s “Score” on those audit
questions which cover site wide PSM “Systems”, as well as for individual PSMs and document /
point out any opportunities for improvement.
2. Each audit area will be provided the audit questions that they will be audited on at least two
weeks prior to the audit. Representatives of the audit team will then meet with appropriate area
personnel (as determined by the Audit Team leader) to:
 Review the area status versus each of the questions.
 Field verification as appropriate the area’s responses to the questions.
 Interview a few selected personnel per the audit protocol and
 Assess the area’s “Score” on each question.
3. Scores are derived by evaluating the "Quality" of the PSM program in place. Quality is determined
by evaluating and determining the percentage of compliance of each of the following:
 Reviewing the written programs and procedures against the requirements of the Corporate
PSM Standard and Level-2 / 3 procedures and OSHA Regulation 29CFR 1910.119.
For example:
a) Are procedures in place for reviewing and authorizing tests?
b) Is there a procedure in place that specifies what is to be included within Operating
Procedures and the frequency at which they are to be reviewed?
c) Is there a procedure in place which specifies how to conduct a Process?
d) Hazards Analysis (PHA) and what is to be included in the PHA Report, etc.?
 Reviewing the extent and quality of the "field" documentation / implementation required for
compliance with the programs and procedures - e.g., Test Run, Temporary Repairs, Operating
Procedures, PHA's, etc. Also, closure of each recommendation/item should be evaluated.
 Interviewing appropriate personnel regarding their knowledge of and compliance with the
programs and procedures. For example, when would a Test Run Authorization or Subtle
Change approval be required, where do you find Operating Procedures and specific
information included within them, how are PHA recommendations closed, etc.
Note: In order to score 100% on any question, the program or procedure must be
documented; field documents must be available; documentation must include the specified
information and be current; recommendations must be closed in a timely manner; and
relevant personnel must be knowledgeable of the requirements of the program or
procedure.
4. Within two weeks after each audit, the PSM Element Audit Team will issue a summary of the Key
Learnings to all relevant interfaces including Safety Advisor / Managers, PSM Sub Committee and
Manufacturing HSE. The summary should include strengths and opportunities for improvement
(recommendations to improve the area or site PSM program or implementation-these should be
as specific and direct as possible) and "scores".

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5. The Safety Section will be responsible for follow up on all the recommendations and “Tracking”
them to closure in a timely manner. Actions / steps taken to address recommendations are also
to be documented.
6. “Highlights” of the audits and the overall “Plant Composite” score on each set of audits will be
presented to PSM Sub Committee and Manufacturing HSE.
7. Copies of audits and the documentation on the disposition of their recommendations should be
maintained for at least six (6) years in the Safety Section files per the requirements of 29 CFR
1910.119.
8. Manufacturing HSE is responsible for providing adequate and appropriate training of the audit
teams on the audit process and questions, both initially and on an ongoing basis. This should
include review of exactly what is to be done during each audit, in-depth discussion of the audit
questions and their intent, review of the scoring criteria, regular monitoring of audits, etc.
9. If an alternate approach acceptable to the team, is raised in the meeting, it should be added to
the report as an addendum.

13.4 Audit Report


The PSM audit report should have the following format:
1. Executive Summary.
2. Overall audit score and comparison with previous years.
3. PSM wise score and comparison with previous years.
4. Strengths.
5. Areas of improvement.
6. New and pending recommendations and their status.
The audit report shall be retained for at least 10 years for record purpose.

13.4.1 Presentation
1. The audit team should present the findings and recommendations to the Manufacturing HSE.
2. If the recommendation is rejected, then a document prepared by the management, recording the
basis for rejection must be placed in the file.

13.5 Recommendations
The Safety Advisor would prepare an action plan on the audit recommendations with the
concurrence of Department Managers.

13.5.1 Tracking and Close Out


1. The Safety Advisor would present the status of recommendations for review in relevant Sub HSE
and Manufacturing HSE on half yearly basis.
2. All recommendations should be closed out within the assigned target date.
3. Recommendations closure documentation shall be retained.
4. All pending recommendations would be added in the next year’s audit report. This will ensure
that none of the pending recommendations are dropped without closure.

13.5.2 Waiver Requirement


1. At times some of the approved recommendation might be found not workable and dropped.
2. This change should be documented, associated risk understood and a waiver taken from
Manufacturing HSE Chairman specifying the reason for dropping out the recommendation.

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SECTION-14 PSM EXTERNAL AUDITS


1. The external audits will be conducted by a professional / team of professionals from
outside EPCL who have in-depth knowledge of PSM systems. Such audits provide an
"outside view" on how the Site is doing and provide opportunities for two-way "sharing"
of good ideas and practices
2. The site should provide qualified personnel (as team members) to assist the external
audit team for conducting the audit.
3. The site must complete external audit at least every three years. Manufacturing HSE
Chairman is responsible to comply with this requirement.
4. In case, the audit cannot be arranged at the required frequency, due to some
unavoidable circumstances, the Manufacturing HSE Chairman may give a waiver
specifying reasons why the audit could not be conducted as per schedule. New program
for the audit should also be specified in the audit report. However, such audit waivers
shall be shared in Corporate HSE committee.

Note: The audit report should be presented in Sub Committee PSM and/or Manufacturing
HSE. Protocol for audit report presentation, action plan, tracking and close out of
recommendations and waiver requirements as described above for internal audits will be
applicable.

SECTION-15 AREA AUDITS

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Self-analysis facilitates implementation of recommendations from an audit, reinforces


understanding of priorities, and prepares the area for internal / external audits.

1. The area Unit Manager should ensure that audit of PSMs relevant to his area is
conducted thru line organization.
2. The audit frequency should be at least once a year.
3. Team must include personnel who are knowledgeable in the process and may include
members from site’s Sub-HSE committee (PSM).
4. The audit recommendations should be addressed within the assigned target date to
ensure safe operations and better score in site’s internal / external PSM audit.

SECTION-16 HAZARDOUS SUBSTANCES SURVEY

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EPCL is committed to the safe operation of its facilities. This commitment requires that all
potential safety hazards are systematically identified and the risks from these hazards are
managed in such a way that the employees, the public, and the environment are protected.

16.1 Objective
The primary objective of the survey is a realistic appraisal of activities and conditions related
to handling and storage etc. of hazardous substances and pointing out areas for
improvement. Auditors should be carefully chosen with expertise to know what to look for
and to recognize deficiencies when they exist. The audit is conducted using a checklist
approved by Sub-HSE committee (Environment and Industrial Hygiene) and available as
Level-3 document.

16.2 Hazardous Substances Basis and Guidelines


EPCL handles a number of substances / chemicals at its Site. To handle these substances /
chemicals safely, following should be in place:
1. Hazards of all chemicals / substances should be clearly defined.
2. Requirements for safe handling, transportation, storage and usage should be clear defined and
understood.
3. Training and audit requirements and frequencies to be documented.
4. Emergency Response protocol should be established.
5. Safe disposal of substances / chemicals to be defined.

16.3 Hazardous Substance / Chemicals


Following substances and chemicals are handled in bulk quantity at EPCL site or they are
part of the manufacturing / maintenance process:
1. VCM
2. Chlorine
3. Hydrogen Gas
4. Sodium Hypo Chloride
5. Ethylene
6. Ethylene Dichloride
7. Sulfuric Acid
8. Hydrochloric Acid & HCl Gas
9. Sodium Carbonate
10. Barium Chloride
11. Sodium Sulfide
12. Ferric Chloride
13. Caustic Soda
14. Asbestos (Use of asbestos related items have been discontinued except asbestos sheets)
15. Water Treatment Chemicals
16. Lab. Chemicals
17. Catalysts
18. Filter Media

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19. Fuel and Lubricant


20. Compressed Gases
The Hazardous Substances survey evaluates the Site’s capability to manage the hazardous
substances and identify any gaps / areas for improvement.

16.4 Hazardous Substances Survey Methodology


16.4.1 Score
1. Numerical scores permit auditors to distinguish between areas of strength and weakness without
preparing long detailed lists of specific deficiencies.
2. Numerical scores also permit comparison with previous scores. However, once the scoring has
pointed to an area of deficiency, attention should focus on actual improvement in the work place.
Where a given subject shows as a widespread weakness, management should develop
appropriately broad corrective action.
3. Auditors and Supervisors should be oriented to see that a correct low score is a helpful stimulant
in support of needed action. A lax audit with unmerited high scores can be a dangerous sedative
which encourages an accident. Revising the scoring procedure to give more credit for the job
partially done might simply ease acceptance of less than desirable standards of safety.

16.4.2 Team and Training


16.4.3 Team
The team leader must have previously participated in the survey as a member.
The team must have representation from different areas which have to be audited. The team
should contain people from supervision and few from operating levels.
A typical hazardous survey team would have 06 members with the following qualifications:
1. Team leader (with previous survey experience).
2. Safety Engineer / Supervisor, if team leader is non-safety / environment resource.
3. Environment Engineer.
4. Operations Engineer.
5. Ware House Engineer / Supervisor.
6. An Area Operator.

16.4.4 Training
1. Team members should receive overview training using the Guidelines and the Checklist.
2. The Hazardous Substances Survey leader should train the team using this guideline, checklist and
based on his experience in a previous Hazardous Substances Survey.
3. Adequate training of the survey team must be done to ensure a high quality audit. Training is
most effective when provided shortly before the beginning of the study.
4. Team training requirements typically include a team resource, or the leader, with in-depth
knowledge of the Hazardous Substances Survey methodology and experience in applying the
method.

16.4.5 Employee Interviews


When interviewing employees it is important to interview a mix of new and experienced
employees. This would provide a better qualitative analysis.

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16.4.6 Area Audit


When auditing different areas it would be more beneficial to use members who are not from
that area, this brings the advantage of a new pair of eyes looking at the area from a different
perspective.

16.4.7 Survey Timing


1. The survey can be conducted using a dedicated team which is spared for a specified time to
conduct an audit which is called an “All-Out” approach. The advantage is the team has a specific
mandate to complete the audit in a specified time and produce the result. Such audits should be
planned at the end of year so as to ensure that all the recommendations from the previous audits
are completed. Generally such an audit can be completed within two weeks.
2. The other method would require various sections of the survey to be audited at different times,
with the overall score for a given year being built up in a cumulative process. This is called
“Continuous” approach under which several teams handling different subjects could conduct
their sections of the audit independent of each other, on an area by area schedule, over an
extended period. This approach avoids some of the problems inherent in making qualified
auditors available for a single “all-out” audit effort. It also permits making audits with little or no
advance notice, and results should be more indicative of the normal state of the operations.
Scheduled audits tend to show an operation on “Dress Parade”, rather than the organization at
work.

16.5 Hazardous Substance Survey Report


The Hazardous Substance report should have the following format:
1. Executive Summary
2. Overall score and comparison with previous years
3. Sections wise score and comparison with previous years
4. Areas of improvement and deterioration
5. New and pending recommendations
6. Filled checklist as an attachment.
The audit report shall be retained by safety section for at least 05 years for record purpose.

16.6 Recommendations
Recommendations are made to reduce an existing risk when it is at an unacceptably high
level. The following facts should be considered before giving a recommendation:
 Clearly addressing a deficiency against a clause of the checklist.
 All recommendations should be based on a good sample size.
 Degree of risk.
 Do ability.
1. When the team considers a non-compliance and concludes that a recommendation is
appropriate, the recommendation should be specific and doable.
2. In general, the team should not make recommendations to “study”, “consider” or “investigate” a
situation.
3. In documenting recommendations in the Hazardous Substances Report, each recommendation
should be listed against the relevant clause.
4. Recommendations from the survey should be categorized as given below. The category assigned
to a recommendation will be based on team’s judgment.

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16.6.1 Procedural
All the safe guards which can be achieved by providing an approved procedure, standing
order or instruction fall under this category.

16.6.2 Simple Jobs


Any recommendation which can be complied with by doing routine maintenance or a minor
job which does not require engineering; fall under this category.

16.6.3 Turnaround Jobs


All the jobs which cannot be handled on a running plant and can only be worked on during
a Shutdown or Turnaround are covered in this category.

16.6.4 Engineering Jobs


Recommendations requiring engineering would fall under this category and would have to
go through the control of change protocol.

16.6.5 Timeline for Different Categories

Category of Job Maximum Time


Procedural 02 months
Simple Job 04 months
Turnaround Job Next Turnaround / FAO
Engineering Job 01 Year

16.6.6 Approval
Recommendations from a hazardous substances survey must be reviewed and approved by
the Manufacturing HSE. The action plan should be developed after getting concurrence from
all the relevant interfaces and stewarded in Manufacturing HSE.
Some of the reasons for rejecting a recommendation are as follows:
1. The analysis upon which the recommendation is based contains factual material errors.
2. An alternative measure would provide a sufficient level of protection.
3. The recommendation is not feasible.

16.6.7 Tracking and Close Out


1. A quarterly status report should be issued by Safety Section to all the relevant interfaces
with copy to Department Managers.
2. All recommendations should be closed out within the assigned target date.
3. All pending recommendations would be added in the next year’s audit report. This will
ensure that none of the pending recommendations are dropped without closure.

16.6.8 Waiver Requirement


At times some of the approved recommendation might be found not workable and dropped.
This change should be documented, associated risk understood and a waiver taken from
Manufacturing HSE Chairman. Recommendations extending beyond the maximum time for a
category would also require a waiver, which should be taken from the respective
Departmental Manager 1st Time (For 2nd time HSE Chairman). For details refer to Site Safety
Manual – HSE Waiver Procedure

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SECTION-17 SAFETY CRITICAL SYSTEM AUDIT


This section describes the Safety Critical System Audit and Scoring procedure to ensure the
implementation of System in a standard way at all Operating Units. SC System Audit is done
to ensure that compliance to SC system is good.

17.1 Team Nomination and Preparation


1. A team shall be nominated by Respective Operation Manager for the safety critical
auditing comprising of one Shift In-charge, Operations engineers / Supervisors, Safety
Resource, Maintenance and Inspection, Instrument and Electrical personnel.
2. Respective Operation Manager will nominate a leader for the audit team who shall be
responsible for audit coordination, completion and report issuance. Team members will
assist him in this regard.
3. All other support functions e.g., I&E, maintenance, inspection, machinery shall help and
fully participate in safety critical system audit, if required.
4. Production management shall also establish the process used for safety critical auditing,
data collection, interviews to be conducted etc.
5. Safety critical audit shall be carried out at defined frequencies; the time interval between
two audits shall not be more than 01 year.
6. Safety critical audit shall be shared with Manufacturing HSE through a report or a formal
presentation.
7. Recommendations of safety critical system audit shall be followed up by the Operation
Unit Managers till completion.
8. To make audits consistent, specific checklists shall be used for interviews and individuals
be scored on those sheets.

17.2 Audit Procedure


1. All the safety critical system aspects shall be covered in the audit.
2. Sufficient people at every level (Managers, Section Heads, Unit Managers, shift in-
charges, shift Supervisor, I&E Supervisor, Maintenance Supervisors, operator and
technicians etc.) shall be contacted and interviewed. Specific questionnaires can be used
for interviews.
3. Interviews shall be started from operator / technician level and shall be continued up-to
at least Unit Manager Level.

17.3 Deficiencies and Report Writing


1. The audit team shall categorize all the deficiencies in various categories, which shall be
given in safety critical audit report.

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2. Deficiencies shall be noted down and shall be used for reporting and must be tracked till
completion.
3. All Managers, Unit Managers and Section Heads will ensure that the deficiencies are
removed in a reasonable time and communicate the status of completion.
4. Record of safety critical system audit shall be kept for sufficient duration to analyze safety
critical system recurring deficiencies. Respective Operation Manager will keep such
records with him; audits can also be kept on HSE Portal.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed

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