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National Safety Council, India

EXAMINATION OF DOCUMENTS

National Safety Council

India
AKSHAY V. HOTKAR
Assistant Director
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National Safety Council, India

CONTENT OF SESSION
Importance of Documentation Checking

Pre-audit Preparation for Document Checking

Documentation Checking During Audit

Difficulties Faced During Document Checking

Types of Documents Required by Statutes

What to be Checked in Documents 2

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National Safety Council, India

Aspects of Safety Audit

▪ Field Visit

▪ Examination of Documents

National Safety Council, India

Importance of Documentation Checking

helps to verify legal compliances (eg. Licenses, authorizations, etc.)

Documentation is an evidence of history of work performance, hence it reflects organisation’s level

of performance in safety mgmt system (eg. Maintenance Records, WPS, medical records etc.)

helps to verify implementation, effectiveness & monitoring of safety mgmt system (eg. Safety
Audit, Safety Inspection, MOM of Safety Committee Meetings & their compliance reports)

confirms what auditee says (eg. PTW, safety manual)

Preparation of audit report writing – indicating compliance & non compliance with references

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Pre-audit Preparation for Document Checking

Asking pre-audit information from auditee organisation by sending checklist for getting details

Assessing pre-audit information of auditee organisation (helps to select audit team members -
construction site, engineering plant, chemical plant, office, etc)

Distribution of elements among the auditors by LA

Preparation of checklist by individual auditor for their allotted elements

Noting Applicable statutes to auditee organisation (type of industry, storage quantities, site of work)

Collecting information(requirements- applicable statutes)

Deciding Audit scope(plant / department / area / element)

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Pre-audit Preparation for Document Checking

Deciding departments / units / bldg to be visited (eg. Mechanical maintenance,
electrical dept, operation dept., stores, safety dept., fire dept, HR etc.)

Forms for documenting observations & supporting evidence.

Preparing audit schedule for document verification

Sending document checklist (IS 14489) well in advance / before the field
visit to the coordinators of auditee

Asking coordinators to collect and keep document at one place for smooth running
of audit
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National Safety Council, India

Documentation Checking During Audit

Documents / records should be checked on a sample basis (lifting m/c, tackles, PV, medical
examinations, etc.)

Ensure that all documents have been produced by auditee as per your checklist & checked
by you

Information provided on documents should be cross verified on site & vice –versa (eg.
storage qty of gas cylinders, Work permits, SOPs etc.)

Collecting soft / hard copies of documents as evidences

Insist an original records / documents for checking

Photos as proof / evidences (especially at construction site, dangerous situations)

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Difficulties Faced During Document Checking

Documents not
Coordinator
in legal For getting
Less time / shows their
Inadequate Confidentiality formats (test documents
manpower own document
nos. of of company reports of repetitive
allotted for instead of
coordinators documents lifting m/c, follow ups may
audit asked
accident be required
documents
register etc.)

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National Safety Council, India

Difficulties Faced During Document Checking

Checking of
Required to
Auditee huge
visit many
Non Willingness divert the Ensuring the documents
departments
availability of person to mind of authenticity Site visit – (Safety Personal
(HIRA, test
concern produce auditors of constraints Manual, relationship
reports of
person documents (intend to documents ERP, QRA
lifting m/c
pass time) etc) – time
etc.)
constraint

National Safety Council, India

Types of Documents to be Checked During Safety Audit

1.
2.
LICENSES /
STUDY / SURVEY
CONSENTS /
REPORTS
AUTHORIZATION

3. 4.
OPERATIONAL RECORD
RECORD KEEPING

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National Safety Council, India

TYPES OF RECORDS TO BE EXAMINED

DURING THE SAFETY AUDIT IS 14489
1) safety policy
2) Safety organization chart
3) Training records
4) Record of plant safety inspections
5) Accident investigation reports
6) Accidents & dangerous occurrences
7) tests and examinations of equipment as per statutes
8) Safe operating procedures
9) Record of work permits
10) Record of monitoring of flammable & explosives
substances at work place
11) Maintenance & testing records of fire detection & fire
fighting equipment
12) Medical records of employees
13) Records of industrial hygiene surveys (noise,
ventilation & levels, illumination levels, airborne &
toxic substances, explosive gases)
14) Material safety data sheets
15) On-site emergency plans & records of Mock Drills
16) Records of waste disposal
17) Records of effluent discharges to the environment
18) Housekeeping inspection records
19) Minutes of safety committee. Meetings
20) Approval of layouts & other approval from
statutory authorities
21) Records of any modifications carried out in plant /
process
22) Maintenance procedure records
23) Calibration & testing records
24) Shut down maintenance procedures
25) In service inspection manuals, records including
that of material handling
26) Safety budget
27) Inspection books & other statutory records
28) Records of previous audits
29) Safety in transportation of hazardous substances

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1. LICENSES / CONSENTS / AUTHORISATION

Factory license

Licenses for explosives

Licenses for boilers

License for electrician – working on LT / HT lines

Air, water consents

Hazardous waste, biomedical waste authorisation of auditee organisation &

disposal agency etc.

Licenses of petroleum storage

Licenses for gas cylinders

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National Safety Council, India

EXERCISE 1-
Petroleum storage in the tanks in plant 1, 2, 3
Plant 1 900 ltr 900 ltr 800 ltr 40KL 5000 ltr
(Mumbai) Diesel- Diesel Diesel LDO Petrol
HSD - HSD - HSD

1200 ltr 900 ltr 45KL 25 ltr

Plant 2
Diesel - Diesel - Petrol
(Indore) LDO
HSD HSD

Plant 3
2200 ltr 50KL 30 ltr
(Jaipur)
Diesel - LDO Petrol
HSD

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National Safety Council, India

EXERCISE 1-
Petroleum storage in the tanks in plant 1, 2, 3
Plant 1 900 ltr 900 ltr 800 ltr 40KL 5000 ltr
(Mumbai) Diesel- Diesel Diesel LDO Petrol
HSD - HSD - HSD

1200 ltr 900 ltr 45KL 25 ltr

Plant 2
Diesel - Diesel - Petrol
(Indore) LDO
HSD HSD

Plant 3
2200 ltr 50KL 30 ltr
(Jaipur)
Diesel - LDO Petrol
HSD

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National Safety Council, India

Exercise 2
No. of Gas cylinders available in plant 1, 2, 3

LPG H2 Cl2 NH3 N2 Acetyle

ne
plant 1 6 (19.2 36 10 4 210 20
Kg each)

plant 2 5 (19.2 20 5 6 180 27

Kg each)

plant 3 8 (19.2 24 15 10 90 24
Kg each)

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No licence needed for filling & possession
in certain cases (GCR-Rule 44 )
Sr Content Does not exceed at a time Examples
no
1 LPG 100 kg LPG
2 flammable but 25 nos. of cylinders / total wt H2
non-toxic gas of gas 200kg, whichever is
less
3 non-flammable & non- 200 nos. of cylinders CO2, N2, He
toxic gas
4 toxic gas 5 nos. of cylinders NH3, Cl2
5 acetylene gas contained in 25 nos. of cylinders acetylene
cylinders in dissolved
state

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National Safety Council, India

1. LICENSES / CONSENTS / AUTHORISATION

Checkpoints….
Whether License obtained from authorized agency / organisation?

Checking validity as on date

If license not valid as on date, then whether application has been made for
renewal

Whether requirements mentioned in the document are fulfilled by the

management? (eg. hazardous waste, petroleum license, gas cylinder license)

See the compliance report of requirements mentioned in the document available?

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2. STUDY / SURVEY REPORTS - Checkpoints….

Hazard Identification & Risk Assessment:- HIRA, HAZOP, QRA etc.

Illumination survey

Ventilation survey

Ambient air quality, workplace monitoring & stack monitoring records

Noise survey

Structural Stability certificate

Identify causes of accidents

Safety Report -- should be available & contents as per the schedule of MSIHC / CIMAH Rules & should be submitted
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to
CIF

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National Safety Council, India

MSIHC 1989 / CIMAH Rules - SCHEDULE II & III

Sr Chemicals Threshold Quantities Threshold Quantities
(tonnes) rules 4,5,7 to 9 (tonnes)
& 13 to 15 rule 10 to 12
1 Chlorine 10 t 25 t
2 Hydrogen 2t 50 t

3 Ammonia 50 t 500 t

• prepare on site • Fresh Safety

emergency plan Audit- Every Year

• mock drill once in 6 • Preparation of

months Safety Report

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2. STUDY / SURVEY REPORTS

Lifts, Lifting m/c & Tackles
• Test records of Lift, Lifting m/c and tackles by CP in FORMS (Cross check SWL with ID at site)
• Competency record of CP
Testing & Examination of Pressure Vessel
• Test records of PV by CP in FORMS (Cross check SWP with id at site)
• Competency record of CP
Testing / Examination of Gas Cylinder (should know requirements)
• Hydrotest Test records by authorised agency in FORMS
• Competency record of authorised agency
Medical Examination
• Record of periodical medical examination of workers involved in hazardous process & Health register? (Sec 87 of FA,
1948)
On Site Emergency Plan
• should be available
• contents as per the schedule of MSIHC / CIMAH Rules
Mockdrill Report:
• (once in 6 months) should be available
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2. STUDY / SURVEY REPORTS Checkpoints….

• crane operators, locomotive, forklift drivers & their signallers should
Specific Medical undergo eye sight & colour vision
Examinations • Canteen staff (food handlers)
• Audiometry test for Workers working in high noise area etc.

• Earthing, Transformer, Transformer Oil, Relays, Circuit Breakers, Isolator,

Test Report-Electrical Lightening Arrestor, Capacitor Bank etc.

• Previous Safety Audit / Inspection reports

Safety Audit & Inspection • Frequency of Audits / Inspections
• Action plan (CAPA) with responsibilities & timeframe
(Internal & External) • Status of compliance report of observations (open & closed status)

• Check whether all applicable study / survey reports available

• Check whether study / survey reports as per statutes
Other Points • Check whether factors / elements mentioned in the reports are well within
threshold limits mentioned in statutes (eg. Noise, illumination, etc)
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3. OPERATIONAL RECORD

Safe
Operating Safety
Procedure Manual
(SOP)

Work Permit Maintenance

System Records etc.

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3.OPERATIONAL RECORD - Checkpoints….

Whether checkpoints TREM CARD
on the documents are
existing on site?
(WPS, SOP etc.)

driving license,
certificate of
Training record of
available in drivers registration, certificate
Driver about TREM
cabin of taxation, vehicle
Whether these card
insurance, fitness
records are reviewed certificate
& revised periodically
by competent team?
(WPS, SOP, Safety
Manual)

Whether all factors /

elements /
checkpoints have
been considered in
these documents?
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4. RECORD KEEPING - Checkpoints

• Prepared as per FA & State Factories Rules
OH&S Policy • Policy availability in English & local language
• Displayed at conspicuous places

• Formation of safety committee (equal representatives

Safety Committee from worker & management)
Meeting • Circulation of agenda of meeting
• Minutes of meeting – frequency of meeting

• Reportable accident & Dangerous occurrence Reported

Accident Record by manager
• Accident register

• No. of first aid box & its content

First Aid • Notice regarding first aid incharge
• List of qualified first aiders with required no.
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4. RECORD KEEPING – Checkpoints..

• Safety induction records & its module & coverage
• Yearly safety training calendar & its compliance
• Modules of safety topics (such as chemical safety, electrical
Training safety, material handling, Work permit system etc) & their
Records coverage
• Review & revision mechanism of training module
• Policy in training & its implementation
• Involvement of safety officer & safety committee members

• Documents of promotional activities (NSD, WED, RSW, FSW) &

safety awareness of workers (involvement of safety officer &
safety committee members)
• Designated Electrical Safety Officer
Others Points • MSDS- copy available for all chemicals
• Disposal records of lead acid batteries, hazardous, biomedical
waste etc.
• Notice of change of manager
• Annual Return, environment statement
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THANK YOU
…..Your safety is our passion…..

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