Bureau of Safety and Environmental Enforcement Safety

Management System Auditing Criteria and Checklist

Introduction
Safety Management System Auditing Criteria and checklist was requested to be provided by the Bureau
of Safety and Environmental Enforcement (BSEE) as part of the contract to develop an example Safety
Management System (SMS) for a hypothetical wind farm.
The purpose of the SMS Audit Program is to provide a systematic assessment of the consistent and
effective implementation of the SMS and to confirm that the SMS itself meets BSEE expectations.
Auditees should ensure that potential or actual weaknesses in the SMS, or in its implementation,
identified in the audit are remedied through effective follow up of the audit findings and assure compliance
with applicable laws and regulations.

Audit team Competency

Personnel assigned to carry out audits will have sufficient experience, knowledge or training of the
standards applied and lease owner specific requirements to enable proper examination of the activities to
be carried out. He/she will also have had completed an internal auditor training course to demonstrate
that an acceptable level of understanding has been achieved. Auditors should have 3 years EHS work
experience or 5 years of operational work experience, and be proficient in the core competencies of
technical, analytical, and communications (interviewing).

Reporting and Documentation of Audit

SMS audits conducted by BSEE will assess the scope, content and effectiveness of implementation of
the local SMS assessed against 30 CFR 585.10. The audit shall cover SMS aspects of the company or
location and interfaces with authorities, contractors (e.g. maintenance, projects, waste), customers, and
the public. All elements of the SMS will be assessed to assure that they comply with BSEE guidelines and
are fit for purpose. A key element will be verification that an adequate internal audit system is being
operated. Special key programs will be assessed for compliance with regulations, permits and/or
standards.
SMS documents, files and records will be reviewed as well as interviews of personnel at facility/business
to verify implementation of the management system and associated procedures.
The Auditor(s) will examine objective evidence to establish compliance and identify potential areas for
improvement. The audits conducted will examine the company SMS against 30 CFR 585.810 which
specifically requires the following:
a)

How you will ensure the safety of personnel or anyone on or near your facilities;

b)

Remote monitoring, control, and shut down capabilities;

c)

Emergency response procedures;

d)

Fire suppression equipment, if needed;

e)

How and when you will test your Safety Management System; and

f)

How you will ensure personnel who operate your facilities are properly trained.

The auditor will note observations made when carrying out the audit on the "Audit Checklist" making
reference to the appropriate procedure or process.
All non-conformities identified are recorded on corrective action reports to establish root cause(s) and
corrective actions required to prevent recurrence. Corrective actions will address systemic errors.
Timescales are to be agreed between the auditee and the auditor.
The auditor will assess the defined corrective action through to satisfactory conclusion. Evidence of
follow up is recorded on the corrective action request and observation sheet as appropriate.
All audit records will be retained.

General Expectations and Corrective Actions

At the conclusion of the each SMS audit a draft report identifying the audit findings and noteworthy efforts
will be prepared. The Findings should begin with an opening statement that is the bottom-line message.
The finding statement should be supported by observations and/or examples of facts. Provide the
regulatory citation or reference to company standard to the lowest level of detail possible. Either quote or
briefly paraphrase the part of the requirement that shows a clear link to the observed non-conformance.
Provide a recommendation that incorporates systematic processes that will prevent reoccurrence.
Corrective action must be taken to address the findings if applicable. Within 30 calendar days from the
date of the closing conference, the auditee should develop a Detailed Corrective Action Plan (CAP) for
all findings. Actions resulting from Findings identified during the must be tracked to completion.

a) How you will ensure the safety of personnel or anyone on or near your facilities
Health and Safety Policy

Check if yes

Section of SMS
where located

Comments

Check if yes

Section of SMS
where located

Comments

Does the organization have a health and

safety policy statement that is clear and
unambiguous?

Does it make a clear commitment to

meeting all relevant and current
standards?

Does it make a clear commitment to

continually improving standards?

Has the head of the organization signed

the policy?

Is there a commitment to review the policy

and keep it up to date?

Is there evidence that the policy has been

reviewed within the specified time frame?

Organization, Roles and Responsibilities

Is there evidence that health and safety

role and responsibilities are delegated to
appropriate levels in the organization?

Has a senior member of the management

team been designated to lead on health
and safety?
Is there a clear organizational structure
that is capable of implementing the health
and safety responsibilities of the
organization?

Is it stated that appropriate resources will

be utilized?

Communication

Check if yes

Section of SMS
where located

Comments

Check if yes

Section of SMS
where located

Comments

Check if yes

Section of SMS
where located

Comments

Is there a process to communicate health

and safety information to relevant staff?

Are there criteria setting out when and

how managers are expected to formally
discuss health and safety matters with
their staff?
Is there evidence that tool box talks occur
regularly and that a H&S committee
exists?
Hazard Identification and Risk
Management
Are there systems in place to identify
hazards and assess risk in the
organization?

Is there evidence that hazards are

identified and risk assessed throughout
the organization?

Is there evidence that the risk assessment

process feeds into control measures and
safe systems of work?

Are there systems in place to monitor the

effectiveness of the controls?

Is there evidence that the effectiveness of

the controls is monitored?

Is there evidence that risks identified are

influential during the making of key
decisions at senior management level?
Management of Change
Is there evidence that changes in health
and safety information are identified and
communicated to relevant staff?

Is there evidence of documentation of

communication of change?

Safe Work Practices

Check if yes

Section of SMS
where located

Comments

Check if yes

Section of SMS
where located

Comments

Check if yes

Section of SMS
where located

Comments

Are safe work practice procedures outlined

in the SMS?

Is there evidence that other documents

cover the work procedure in a thorough
and simple manner?

Environmental Management

Is there a separate document that outlines

the policies and procedures that outline
management of permitting and spills?

Measuring Performance

Does the organization have key

performance indicators (KPIs) for health
and safety performance?

Is there evidence that KPIs are used to

improve health and safety performance?

Is there evidence of bench marking

performance?

Is there evidence of reactive monitoring of

health and safety performance?

Is there evidence of pro-active monitoring

of health and safety performance?

Is there evidence that deficiencies in

arrangements identified by monitoring are
acted on?

Are work related health trends monitored?

b) Remote monitoring, control and shutdown capabilities

Check if yes

Section of SMS
where located

Comments

Is there a description of how the wind farm

will be operated remotely and provisions
for control and shutdown procedures?

c ) Emergency response procedures

Is there a section of the SMS that

describes the emergency response
procedure?
Is search and rescue referred to and is
there evidence of a second, separate
procedure that was developed in
conjunction with the USCG?

d) Fire suppression equipment, if needed

Is there a description of any fire

suppression equipment located on the
turbines and substations?

e) How and when you will test your SMS

Reviewing and Auditing

Are there arrangements for reviewing the

organizations health and safety policy?

Are there arrangements for reviewing the

organizations health and safety
performance?

Check if yes

Section of SMS
where located

Comments

Is there evidence that senior managers

review the health and safety performance
of the organization?

Is there evidence that the review feeds

into future plans and strategies?

Is there evidence that a review of an

individuals performance includes
consideration of their health and safety
performance?
Are there arrangements for reviewing the
adequacy of the health and safety
organizational structure?

Are there arrangements for reviewing the

adequacy of the health and safety
planning arrangements?

Are there arrangements for reviewing the

adequacy of the implementation of health
and safety policies and procedures?

Are there arrangements for reviewing the

adequacy of the measuring/monitoring of
performance arrangements?

Are there arrangements for reviewing the

adequacy of the organizations health and
safety audit arrangements?

f) How you will ensure personnel who operate your facilities are properly trained
Training and Competence

Are health and safety competencies

identified and built into job profiles?

Is there evidence that health and safety

training needs are being identified and
met?

Check if yes

Section of SMS
where located

Comments

Is there evidence that health and safety

training outcomes are evaluated?

Is there evidence that the requirements for

information, instruction and training are
being met?

Are records of individual

training/competency held?