Get the Most out of your Machine-Safety Audit
This is the first part of a two-part series on machine-safety audits. The second part will appear in the April issue of Inside Machines. If you are going to take the time and effort to do something, you may as well do it right” is a simple philosophy that applies to many things, but especially to safety auditing.
This is the first part of a two-part series on machine-safety audits. The second part, "Knowledge and Focus are Key for Effective Safety Audit ," will appear in the April issue of Inside Machines.
If you are going to take the time and effort to do something, you may as well do it right” is a simple philosophy that applies to many things, but especially to safety auditing. A well-prepared and well-executed safety audit program can make a substantial difference in helping companies prevent accidents and injuries. In fact, most organizations with successful safety records have a well-organized safety audit program in place.
To be effective, it is important that organizations understand and incorporate the key characteristics of a successful audit program.
Properly addressing these keys can help ensure that the program will deliver maximum impact with minimal risk, while continuing to add value over time.
1. Plan and prepare
A good safety audit program does not come easily. The effort requires careful planning and diligent preparation.
A good starting point is deciding why you want to do a safety audit in the first place. More specifically, what is it you want to achieve? Answering this question will give your audit focus and purpose. It also provides the foundation upon which the audit program will be built.
Consider the following questions when planning for a safety audit program:
What departments or operations will be covered in the inspection tour?
What items or activities will be checked?
How often will the inspections be carried out?
Who will conduct the tours?
How will the inspections be conducted?
What type of follow-up activity will be put in place so that corrections are, in fact, made?
Does management understand that hazards or unsafe work practices will need to be corrected and that this will require human resources, management and engineering expertise?
As with any well-functioning management system, an audit program must have guidelines and procedures to describe how the audit should be conducted and what corrective action should be taken. These procedures should define all audit activities, such as planning the audit, on-site activities and follow-up. Without written audit procedures, audits will be conducted haphazardly and inconsistently at best, based on individual skills and preferences.
The audit protocol is an important tool that guides the auditor through the audit process. An effective protocol defines the steps that an auditor needs to take in order to audit a particular process or machine, as well as provides guidance on what to look for and where it is located. Some companies use checklists or questionnaires as protocols, which provide a general framework for the areas and activities under review. It's up to the auditor to probe deeper into these issues for a thorough evaluation of each area.
In the planning stages, key employees should be involved to make sure that all safety programs, operations and hazards are addressed. This may involve discussions with the safety department, frontline employees and company managers to be sure all areas they consider to be high priority are included. While it is important that nothing is overlooked, companies need to be selective and make strategic decisions about what areas will be reviewed. The goal is to spend time auditing things that have high impact and probability, such as electrical and explosive materials, machine guarding, and the use of personal protective equipment. This will help ensure that audits have the greatest return.
2. Define the scope
A successful audit inspects the right things. Clearly, you cannot audit everything; therefore, it is important to prioritize the areas of focus. Too often, the audit team is constrained by how much time the audit can take or by the very size of the audit team. This can result in an insufficient amount of time available to dig deep enough to uncover issues other than those that are obvious, such as employee training and safety awareness.
Identifying key risk criteria can be helpful in evaluating individual subject areas and assessing their levels of scrutiny. These criteria include:
Change —History has shown that new or changed processes introduce increased risk. This can include changes to materials, processes, facilities, equipment, people, and even changes in leadership.
Performance indicators — These imply that past performance is a predictor of future performance.
Regulation —In this case, risk is evaluated on whether the subject area is regulated by laws, standards or contractual requirements.
Time —This considers how much time has elapsed since the subject was last audited.
Most audit programs give prominent attention to hazardous conditions that are easy to understand and simple to inspect. This includes subjects like lock-out/tag-out, confined spaces, fall protection, and other items that could cause injury. Too little attention is given to unsafe acts or hazardous behavior of employees, even though accidents can also be due to a bypassed or improperly designed safety system.
Audits typically do not get to these root deficiencies. Therefore, it's important that the inspection program focus on basic items such as new-employee safety orientation, specific training for new jobs and supervisory follow-up. Likewise, since machine and process designers are familiar with many of the risks, they can play a major role in helping to design hazards out of the system through proper selection of the safeguards, as well as controls and barriers best suited for the particular operation or process.
Another important question is whether a general inspection or targeted inspection should be conducted. General inspections are comprehensive reviews of all safety and industrial health exposures in a given area or complete factory. Targeted (or special) inspections deal with specific exposures in a given unit, section or plant. Such inspections might focus on electrical hazards in machinery, or hazards that may have generated specific injuries noted during a review of workers' compensation reports.
A good audit program can include both types of inspections. For example, one month, a program could involve a complete plant tour for safety hazards. During the next month, there could be a focus on personal protective equipment and how it is used.
In fact, OSHA encourages this mixed approach, believing that a combination of the two types of programs can strengthen a plant's accident-prevention effort.
3. Involve the right people
An audit's success relies heavily on involving the right personnel. Variables, such as the size and type of business, number and expertise of employees, and special hazards and characteristics, dictate which staff members should be assigned to the audit program. In many cases, a team approach is used, mixing facility and line managers, supervisors, engineers, operators and staff from other departments.
To determine the makeup of the audit team, consider:
The type of safety audit that will be conducted (general versus targeted);
Experience and availability of employees;
Time requirements and constraints of employees;
Special hazards and operations; and
Experience and cost of outside consultants.
Safety program managers should critically review the audit team makeup for a balance between objectivity and familiarity. Objectivity can be obtained by using staff from other processes that are not included in the current audit or from other facilities. In some cases, companies may prefer to bring in an outside organization to conduct the audit. The biggest advantages to engaging an outside consultant is that they, with greater safety-audit experience, might be able to identify hazards that the internal team failed to detect, and simply because they bring a fresh set of eyes to the situation. They can also provide industry-wide knowledge of procedures and practices that can be used to strengthen an existing safety program.
Either way, it's important that the auditor have experience in auditing techniques, such as prioritization, sampling and following an audit trail. An auditor that is knowledgeable about a particular process or application can be especially effective. When choosing an outside provider, consider their ability to supply audit products, and to address the device selection process. You should also consider the development of new machine safeguarding specifications to help with certification and compliance demands.
4. Corrective action and follow-through
Company management must demonstrate complete commitment and support throughout all phases of an audit, particularly to ensure that action items generated from an audit are adequately addressed. This includes providing the required resources to implement the agreed-upon changes such as personnel or materials.
The bottom line is company leaders must not be afraid to uncover safety deficiencies or shortcomings. Company leaders must be completely committed to doing a safety audit the right way and for the right reasons—not simply because it is a mandate, or because it makes managers look good.
Conducting the audit and reporting the findings is the easy part. The difficulty often begins with following-up on the findings and implementing corrective actions. This is where improvement takes place, changes happen, root causes are eliminated, and controls and safeguards are put into place to prevent recurrence. Audits can be thoroughly planned and professionally conducted, but unless deficiencies are corrected, the effort is pointless.
Typical failures that can occur at the follow-up stage include failure to:
Understand the intent of the finding;
Assign responsibility for following-up a finding;
Track findings to completion;
Document clearly what was done; and
In many cases, companies correct the finding as reported, but fail to spend the extra time and effort to determine whether the deficiency represents a more endemic problem. Without understanding the root cause of the deficiency, the next audit will likely uncover the same problems.
When companies commit to conducting a safety audit, they must be prepared to remedy hazards that are uncovered in the audit process. Safety managers should keep in mind that during an OSHA inspection, investigators can access internal safety and health records, including records of safety audits. OSHA has the authority to issue citations and penalties for safety violations if a company does not act on negative findings.
Therefore, after installing safeguards, it's important to conduct follow-up assessments to verify that the potential risk has been reduced to an acceptable level. Closing the loop means that corrective action has been implemented and then validated and verified. Likewise, periodic assessments of safety methods and practices are important to confirm that specific programs are being followed and remain effective.
5. Train, educate
Reducing potential risk also requires appropriate instruction and training on safety procedures. All employees who may be exposed to the hazards a machine or process presents should participate in these training programs. While the company is responsible for implementing the training, each employee is ultimately responsible for applying the training and safety procedures to their work.
All audit participants should have a fundamental understanding of the safety audit process. At a minimum, they should have an understanding of:
Objectives and mechanics of the safety audit process;
Two basic audit types (general and targeted);
Benefits of safety audits;
Documentation requirements; and
Training needs can be expanded to include specific areas like accident investigations, back injury protection, personal protection equipment, lockout/tagout, and machine safeguarding. The safety director and facility manager are good candidates to develop and conduct training programs. The training agenda and programs must be customized to meet the specific needs of the facility.
Effective safety audits can be an important component of a successful safety program. To realize the full benefits of an audit program, however, it is critical for companies to have the right focus, involve the right people, allocate adequate resources, and follow-through on corrective actions. Those companies with a well-planned and well-executed audit strategy will be the ones that forge a sustainable competitive advantage in the years to come.
- See also the Control Engineering Machine Safety blog .
Steve Dukich is a senior application engineer and Mike Duta is manager, PE of machine safety services, at Rockwell Automation. Contact them through Andrea Hazard at firstname.lastname@example.org .
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