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Canadian

Registered
Safety
Professional

HSE Auditing

Study Guide
Board of Canadian Registered Safety Professionals
6700 Century Avenue Suite 100, Mississauga, ON L5N 6A4

Tel: (905) 567-7198


Toll free: 1-888-279-2777
E-Mail: info@bcrsp.ca
Web: www.bcrsp.ca

Last Revision: 2014


BCRSP Guide to Registration © Page 1
HSE Auditing

HSE AUDITING (AUD)


This domain was developed by Gene Marie Shematek, GMS & Associates, Ltd. Calgary, AB.

Originally Developed: 2005 Last Revision Completed: 2014

Table of Contents
Purpose and Scope ................................................................................................................................................. 3 
Introduction to Auditing Health and Safety Management Systems ................................................................... 3 
Health and Safety Management System Audits Evaluate the OHS Management System ............................... 4 
Organizational Culture and Auditing ..................................................................................................................... 5 
Auditors .................................................................................................................................................................... 6 
Key Elements of Health and Safety Management Systems ................................................................................ 8 
Management commitment ......................................................................................................................................... 8 
Hazard identification and evaluation process ............................................................................................................ 9 
Hazard control ........................................................................................................................................................... 9 
Workplace Inspections ............................................................................................................................................ 10 
Incident reporting and investigation ......................................................................................................................... 10 
Employee Competency ........................................................................................................................................... 10 
Emergency Preparedness ....................................................................................................................................... 11 
System Administration and Quality Control ............................................................................................................. 11 
Audit instruments .................................................................................................................................................. 12 
Overview of the Audit Process............................................................................................................................. 15 
Pre-audit Activities ................................................................................................................................................ 16 
Preparing for the audit .......................................................................................................................................... 17 
Assisting the company with communications .......................................................................................................... 18 
The Audit Plan........................................................................................................................................................ 18 
Auditor Preparatory Tools .................................................................................................................................... 18 
Sampling Tools for Interviews ................................................................................................................................. 19 
Audit Communication Tools ..................................................................................................................................... 21 
Field note tools ........................................................................................................................................................ 21 
Electronic tools ........................................................................................................................................................ 21 
Preparing to go on-site ............................................................................................................................................ 21 
Audit Team Communication .................................................................................................................................... 22 
The “kick-off” Meeting .......................................................................................................................................... 22 
Documentation....................................................................................................................................................... 23 
Conducting the Document Review .......................................................................................................................... 25 
A closer look at the documents ............................................................................................................................... 26 
Quality and contents ................................................................................................................................................ 26 
Currency of documents ........................................................................................................................................... 26 
Time and frequency requirements ........................................................................................................................... 26 
Communication ........................................................................................................................................................ 26 
Life cycle of documents ........................................................................................................................................... 26 
Document specificity ................................................................................................................................................ 27 
Interviews ............................................................................................................................................................... 27 
Interviewing Skills .................................................................................................................................................... 28 
Interview questions .................................................................................................................................................. 28 
Interview Planning ................................................................................................................................................... 29 
Size, structure and geography of the organization .................................................................................................. 29 
Length of interviews ................................................................................................................................................. 29 
Type of interviews (individual, group, or written questionnaire) .............................................................................. 29 
Order of interviews................................................................................................................................................... 30 
Background information about departments and employees .................................................................................. 30 
Location of interviews .............................................................................................................................................. 30 
Key questions for various types of employees ........................................................................................................ 30 
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HSE Auditing

Recording information from interviews .................................................................................................................... 30 


Confidentiality of interviews ..................................................................................................................................... 31 
Selection of interviewees ......................................................................................................................................... 31 
Conducting interviews.............................................................................................................................................. 31 
Site Tours – Familiarization Tour ......................................................................................................................... 34 
Site Tours – Observation Visits ........................................................................................................................... 36 
Audit Close-out or Debriefing Meeting ................................................................................................................ 36 
Completing the Audit ............................................................................................................................................ 37 
Scoring an audit (scored instruments) ..................................................................................................................... 37 
Scoring by an Audit Team ....................................................................................................................................... 38 
Scoring Errors .......................................................................................................................................................... 38 
Results Using Un-scored Instruments ..................................................................................................................... 39 
Field Notes............................................................................................................................................................... 39 
Non-conformances and Corrective Action Requests (CAR) ................................................................................... 40 
Recommendations ................................................................................................................................................... 40 
Liability Concerns with Regards to Recommendations ........................................................................................... 41 
The Audit Report...................................................................................................................................................... 41 
The Audit Report Presentation ................................................................................................................................ 42 
Supplemental Reports ............................................................................................................................................. 42 
Action Plans ............................................................................................................................................................. 42 
Auditing the Auditors ............................................................................................................................................ 43 
GLOSSARY of TERMS .......................................................................................................................................... 44 
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HSE Auditing

Purpose and Scope


This guide is intended to provide an overview of the principles and practice of auditing occupational health and
safety management systems. It covers the major aspects of conducting an audit, and is divided into pre-audit, on-
site and post audit activities. This guide is not intended to certify the reader as an auditor, as this traditionally
requires a formal education program in auditing that includes practical exercises as well as the submission of a
qualifying audit. This guide will be helpful to the CRSP candidate in understanding the requirements for the
domain of HSE Auditing (AUD). Occupational health, safety and environment generalists require a fundamental
knowledge of health and safety auditing to evaluate the status of health and safety management systems and
also to help organizations prepare to be evaluated by external auditors. The material for this guideline is derived
from and summarizes the major themes of the following reference text: Environmental Health and Safety
Management Systems Auditing, by Gene Marie Shematek, Paul McLean and Peter Lineen: LexisNexis
Butterworths, Ltd., 2013 Edition. Though the reference textbook refers to Health, Safety and Environmental
Management Systems Auditing, this review focuses on health and safety management systems auditing. As the
principles are the same, these terms will be used interchangeably in this study guide.

Introduction to Auditing Health and Safety Management


Systems
Health and safety management systems refer to the formal structures in place to manage health and safety in an
organization. A management system is a framework of accountabilities to ensure the following critical components
are developed, implemented, and documented:
 there is an effective health and safety policy
 planning occurs to address all aspects of health and safety
 effective practices, programs and procedures are implemented
 performance is measured and monitored
 problems or deficiencies are corrected, and
 the system is evaluated on a regular basis.

Management system audits are designed to evaluate the effectiveness of these complex systems. Often
conducted by external consultants, these audits involve the entire company by assessing the effectiveness of the
processes in place to prevent injuries and improve health and safety in the workplace. Environmental
management system auditing has been well established for many years with standards such as ISO 14001 well
utilized in many industries). Most occupational health and safety management system standards parallel those of
environmental standards, incorporating a continuous cycle of planning, doing work to meet the standards,
checking to validate work done and acting to improve on performance.

The focus on health and safety management systems has been increasing over the past two decades. A greater
emphasis is being placed upon safety as a close relative to quality. As management strategies evolved to meet
current models, new approaches to managing health and safety began to parallel the approaches designed to
manage continual quality improvement of products and processes. As companies and organizations became less
paternalistic or autocratic in their relationships with employees, a culture of sharing responsibilities was
accompanied by a greater awareness of employee rights. The promotion of the internal responsibility system
(IRS) fostered the understanding of this shared responsibility. Health and safety issues were often rallying points
for unions and employees, who demanded more attention to this vital area. The workers “right to know”,
understand and be protected from workplace hazards became enshrined in law, and a new era of communication
and injury prevention arrived.

Legislation has become more aggressive in defining the employer as ultimately legally responsible for worker
health and safety; penalties and increased Workers’ Compensation costs have further focused the attention of
company executives on occupational health and safety. Once a delegated OHS department responsibility and
accountability, occupational health and safety has graduated to the status of being on the radar of company
executives and being “everyone’s responsibility”.
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HSE Auditing

For many health and safety professionals, a major focus has traditionally been on the health and safety programs
in their organizations. These are usually developed to facilitate a specific objective, often compliance with
regulations or best practice guidelines. The basic idea is to identify a prevention-oriented program that is missing
and develop and implement it so that it can work in a specific company. The identification of a missing program is
often facilitated through a review of legislation as well as an analysis of incidents and accidents that a company
may have had and identify what could have been done to prevent them.

Examples of some specific health and safety programs are listed in Table 1.

Examples of health and safety programs

 Accident/Incident Investigation
 Respiratory Protection
 Occupational Hygiene
 Workplace Hazardous Materials Information System
 Workplace Inspection
 Working Alone

Table 1
These programs typically are almost “stand-alone” programs, though they share some common features,
including a policy with designated accountabilities, forms and other tracking/reporting documentation, training
programs, and follow-up requirements. Often these programs are designed and managed by occupational health
and safety professionals, though in more progressive organizations, they are “owned” by line management. There
are also generic programs available commercially that are customizable for the organization.

Inspection Programs
A good example of a health and safety program that is often confused with auditing is the workplace inspection
program. Workplace inspections are systematic reviews of processes, procedures, equipment and materials to
ensure that all potential hazards are being controlled. Generally, the workplace inspection program is developed
by health and safety professionals, and includes a policy that identifies the required frequency of inspections,
designation of those accountable for performing inspections, standardized inspection forms that identify risks that
should be reviewed, classified and corrected, and a reporting and follow-up procedure. In most cases, senior
management is far removed from the inspection process and often is unaware of the results. Inspections are
conducted in specific areas, usually by internal staff.

Health and Safety Management Systems


An occupational health and safety management system is a quality and content control system – making sure all
programs and all aspects of each program are in place and functional at all levels of the organizations. A key
feature of a management system is the system to “close the loops”, ensuring that all aspects of the activity are
carried out, reviewed and acted upon.

As with quality, health and safety in progressive companies is integrated into all aspects of the work. The
infrastructure of accountabilities, program development and implementation, enforcement, and continual
improvement has become the health and safety management system, and underpins the company’s ability to
prevent injuries in the workplace.

Health and Safety Management System Audits Evaluate


the OHS Management System
Evaluating health and safety management systems is an important process to ensure that the fundamental
management infrastructure is in place to effectively manage health and safety. Audits have become a primary tool
for assessing the health and safety management system, with the development of audit protocols and instruments
to meet a variety of objectives. An audit is basically a gap analysis of the status of health and safety management
system elements compared to a set of standards. The set of standards is used as the basis of an audit
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HSE Auditing

instrument, which describes the standard and often identifies information to be obtained about the company’s
status relative to the standard. A variety of audit instruments exists and ranges from general to very prescriptive
documents. The audit instrument also identifies required validation techniques for each standard. These usually
include an examination of company documents, interviews with all levels of staff, or direct observation in the
workplace, and often a mixture of one or more of these validation methods is required.

Companies choose to have audits performed for many reasons, examples of which are listed in Table 2.

Reasons for Conducting HSE Management Systems Audits

 To establish a baseline from which to measure improvements


 As a result of a serious incident
 To comply with a government order
 To demonstrate due diligence
 To benchmark with other company branches
 As part of a financial incentive program
 To enable the company to bid on certain jobs
 For public relations purposes

Table 2
The growth in popularity of auditing has led to a proliferation of audit instruments, auditor certifications, and
certification organizations. In some cases, it is not easy to choose an audit instrument that is most appropriate for
a company’s current management system. Several industry-specific audit instruments are available, and these
use terminology consistent within the specific industry. Some instruments provide scores, while others do not.
Some instruments require reports with detailed recommendations; others may require a list of non-compliances.
The challenge is to select an instrument that will be most beneficial in helping a company improve their health and
safety system. This depends on a number of factors, including the level of internal OHS expertise, the motivation
of the company, requirements for an audit to be conducted, and the current status of the system. In addition, an
organization that is striving to continually improve may choose increasingly sophisticated audit instruments over
time.

Organizational Culture and Auditing


In the introduction section, changes in management style were discussed in terms of their impact on health and
safety management. As organizations and companies have distinct corporate cultures, health and safety may be
managed in different ways over the course of the evolution of the culture.

While audits often provide insight into a company’s culture, the culture also impacts the audit process. The
following table (Table 3) lists several impacts of culture on the audit process:

Impacts of Corporate Culture on the Audit Process

 Executive management may be unavailable for interviews if they do not place a priority on health and
safety or value the audit process.
 Management may attempt to control the audit process.
 Companies with adversarial relationships between management and employees may inhibit honest
interviews.
 Executive management may ignore the completed audit report.

Table 3
In some cases, organizations that have annual audits look for alternatives that may require less time and inject a
fresh perspective on the occupational health and safety management system. If the organization has a good
safety culture and wants to maintain its continual improvement, it may elect to focus on action plans on years
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between formal audits. The action plans are used to supplement and expand upon the audit, by identifying the
high priority audit recommendations and developing detailed action plans, with designated timeframes and
accountabilities for implementation. If a company has specific certification that requires annual audits, this may
not be an option. We will discuss the use of action plans later in this document.

Auditors
The value of an audit is directly related to what the company executive does with the final report. What the
company executive does with the final audit report is directly related to the quality of the audit. Over the years,
many different certification and training programs for auditors have been developed. The quality of auditors is of
paramount importance to the future usefulness of auditing as a tool to improve health and safety. Audits that are
professionally conducted, with reports that are clear, well written, and accurately reflect the status of the health
and safety management system, will be valued by companies that commission them. Audit recommendations that
are feasible and consistent with company culture are more likely to be implemented. To ensure that the audit will
be valued and lead to improvement for the company, it is critical to select a well-trained and experienced auditor.

Auditors may be internal auditors or external auditors. The type of audit or the reason the audit is being conducted
may impact the choice of internal or external auditors. External auditors are often external OHS professional
consultants, while internal auditors are often operational experts working in the company. The following table
(Table 4) identifies advantages and disadvantages of each:

Advantages/Disadvantages of Internal or External Auditors

Professional Auditor - Advantages


 No history with the company
 No vested interest in the audit results
 Familiar with basic OHS regulations and principles
 Trained in audit technical skills (interviews, document review, etc.)
Professional Auditor - Disadvantages
 Not aware of hidden hazards
 May be unaware of industry specific hazards or regulations
 May not understand history of program development
Internal Auditor - Advantages
 Knowledgeable about industry or organization hazards
 Aware of historical information regarding program development
 Understands objectives of organization
 Knows the people
Internal Auditor - Disadvantages
 May be subjective
 Vested interest in the audit results
 May be inexperienced in audit skills
 Position may report to those audited
 May be seen as a policeman

Table 4
Some employers prefer to use external auditors to conduct their internal audits. Reasons for this include:

 The time and effort required to train (internal) auditors


 The perception of bias of internal auditors who may be auditing their own work
 The value of having a third party assessment

For larger audits, audit teams are often used. Audit teams enable the blending of experience, industry expertise,
and professional auditing skills. Audit teams must have a strong team leader and be very well coordinated to
ensure an efficient and effective audit process.
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HSE Auditing

Several organizations have assumed the role of training and certifying auditors. Auditor certification usually
involves an approved training program where all auditor skills are taught and practiced, an exam to verify
knowledge, a signed code of ethics statement, and the submission of a “qualifying” audit that is critically reviewed.
The organizations that certify auditors usually certify them to use a specific audit instrument.

Many organizations or associations that train and certify auditors have requirements for refresher training and
certification maintenance. Certification maintenance usually requires the submission of a certain number of audits
over a designated period of time, attendance at regular update sessions, and the signing of a Code of Ethics. In
addition, some certification bodies require certain scores on quality control reviews.

Table 5 lists the desired personal attributes and ethics of auditors.

Personal Attributes of Auditors


 Open-minded
 Mature
 Possess sound judgment
 Have good analytical skills
 Have tenacity
 Ability to perceive situations realistically
 Understand complex operations from a broad perspective

Ethics
 Honesty
 Objectivity
 Completeness
 Accuracy
 Professional conduct
 Separation of fact from opinion
 Maintain anonymity of interviewees
 Confidentiality
 Avoid disclosing information gained in audit for personal gain
 Avoid conflict of interest

Table 5
For many certification bodies, disciplinary action is possible for auditors who are deemed to be using questionable
practices or have breaches of ethics. Most certification bodies require the auditor to sign a Code of Ethics
periodically. The Code of Ethics may include quality aspects (as indicated above), but may also provide specific
requirements, such as:

 Prohibiting the auditor from auditing an organization for which he or she has provided program
development and other consulting services for a year prior to the audit.
 Restricting auditors from auditing a company with a key employee who is a close friend or family member
 Prohibiting auditors from making recommendations with the intent to market additional services.

Professional auditors may be required to be certified by several different certification bodies to meet the range of
client industries. Some auditors may find it challenging and expensive to maintain many certifications.
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HSE Auditing

Key Elements of Health and Safety Management Systems


The various Health and Safety Management System audits evaluate several common elements. These are listed
in Table 6, below.

Common elements in many health and safety management system audits

 Management policies and commitment


 Hazard identification and evaluation process
 Hazard control process
 Work area inspections
 Incident reporting, investigations and follow-up
 Employee competency
 Emergency preparedness
 System administration and quality control
 Workers’ Compensation Board claims management and return to work processes

Table 6
Management commitment
The foundation of a health and safety management system is executive management commitment to the health
and safety of workers as evidenced by effective systems in place to prevent workplace injury and to continually
assess and improve health and safety in the workplace. The auditor looks for several indicators of management
commitment, including those listed in Table 7.

Indicators of management commitment

 A health and safety policy that is current, communicated to employees, promoted, and enforced
 Strategic direction that integrates health and safety with quality and production
 Health and safety objectives that support the strategic direction
 Specific measurable goals to guide improvement in health and safety
 Designation of roles, responsibilities, and accountabilities to ensure oversight and compliance
 Maintaining health and safety on the management agenda
 Supporting employee health and safety performance through individual evaluations, recognition, and
promotion of involvement
 Provision of appropriate health and safety resources
 A focus on injury prevention and hazard control

Table 7

Management commitment is demonstrated to employees by:

 Management actions – does management obviously support safety in terms of accountability, integration of
safety into management functions, allocation of sufficient resources, and consideration in performance
appraisals?
 What gets management’s attention – does management review leading and lagging indicators of performance
and activities, does management request proactive health and safety advice in purchasing decisions, design
considerations, etc., does management support a health and safety management systems audit and provide
an action plan to address the recommendations?
 What doesn’t get management’s attention – is there a tendency to ignore workplace hazards, housekeeping,
equipment failures, reports of health and safety indicators and activities, and audit reports?
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 What management uses to measure and control – is there a greater emphasis on production and profit at the
expense of employee health and safety?
 How management responds to crises – does management attempt to cover up problems or learn from and
correct errors?

Perception surveys have shown that there is often a discrepancy between the employees’ perceptions of safety
and management commitment to a healthy and safe work environment and the perceptions of management of the
status of safety in the organization and their own level of commitment. This discrepancy is also frequently evident
in the interview phase of an audit.

In some cases, management support may be superficial. This is evidenced by a lack of management
performance measures related to health and safety system activities and a lack of management roles and
accountabilities in all aspects of the program. True management commitment and support can be distinguished
from “token” support by documented OHS performance measures for all levels of management, the establishment
of OHS goals and objectives, attention to OHS performance metrics, and the regular review and updating of OHS
processes and results.

Hazard identification and evaluation process


This critical element is part of the planning process for hazard control. All potential hazards must be identified and
evaluated to enable the implementation of appropriate control measures. A documented hazard identification
process is key to demonstrating due diligence and is a legislated requirement in many jurisdictions. Hazard
identification is made systematic through the use of detailed checklists that provide a template for identifying
chemical, biological, physical, ergonomic, and psychosocial hazards. In developing the checklists, health and
safety professionals review legislation, equipment specifications and maintenance documentation, incident
reports, speak at length with workers who perform the tasks, and observe tasks being performed. Both health and
safety hazards should be included in hazard assessments. Many audit instruments require the assignment of a
risk factor for each hazard. This is usually calculated as a function of the probability of exposure, the severity of
consequences of exposure and the frequency that workers perform the task.

It is important to understand and document the physical requirements for various jobs. Some tasks will become
hazardous if the employee is not able to meet the physical demands of the tasks. Job hazard analyses and
physical demands assessments will assist in the creation of a job hazard inventory, which will allow for a
systematic approach to controlling hazards. In addition, job hazard analyses and physical demands assessments
are also useful in the hiring of qualified staff and in modified work planning for employees returning to work after
an illness or injury. The hazard identification, assessment and control process should include communication of
the information to all staff who occupy the positions assessed.

Hazard control
The major purpose of identifying and evaluating hazards is to determine and implement effective controls that will
minimize employee exposure to the hazards. From the perspective of proving that an employer is duly diligent in
managing health and safety in the workplace, effective hazard control is a critical requirement. Most health and
safety legislation has statements holding employers accountable for ensuring that everything that is practicable
and reasonable is done to ensure the health and safety of workers. Generally, this means that controls must be
employed to reduce or eliminate exposure.

The traditional approach to classify controls consists of engineering controls, administrative controls, and personal
protective equipment. Examples of engineering controls are local exhaust ventilation systems, substitution with
less dangerous chemicals, and isolating the process. Administrative controls usually refer to work scheduling,
training requirements, and workplace safety policies and procedures. Personal protective equipment provides a
barrier at the employee interface with the environment. Usually worn by employees, personal protective
equipment such as respirators, gloves, safety clothing is considered the “last line of defense” to worker exposure.

When auditing, it is important to identify the type of control used, as the most effective controls are engineering or
controls at the source, with the least effective controls being PPE or controls at the worker. Legislation usually
requires consideration of the “hierarchy of controls”, with a preference for controls at the source of the hazard.
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Sometimes employers have identified controls but are not diligent in implementing them and enforcing their use.
The auditor is required to verify that the appropriate controls are implemented and in use, often through a
combination of documentation, interviews and actual observations. Controls also take into consideration legislated
requirements (for example, requirements to have a Code of Practice for specific hazards or controls). When
engineering controls include equipment, a preventive maintenance program may be necessary. When PPE is
required, there may be additional controls related to the selection, use, fit-testing and disposal of the items.

Workplace Inspections
Another control process that assists employers in identifying and correcting hazards is the workplace inspection
process. Many audit instruments include an assessment of the workplace inspection process as a required
element. The standard may require that the process be supported by a policy, with designated roles,
responsibilities, specified inspection frequency, classification of hazards, and follow-up to identified hazards.
Workplace inspections are facilitated by a checklist that covers the site-specific conditions. Employees familiar
with the specific activities conducted at the worksite often develop the checklists. In most good management
systems, the inspection results are documented, with a classification of the hazards and a designated time frame
for corrective action. In addition, a follow-up procedure is implemented to “close the loop” and ensure that the
inspections produce results that are meaningful in reducing injury in the workplace. Auditors often review
inspection reports as part of the document review and make a list of items that were identified as needing
correction, then visit those areas and verify that corrective action occurred. For example, a deficiency identified on
several consecutive inspection reports signals that the corrective action has not been implemented or is not
effective in controlling the hazard.

Incident reporting and investigation


An effective OHS management system enables the development of injury prevention strategies that are based on
best practices, and also takes into account lessons learned from company experience. Incidents often result from
multiple causes that, when occurring in a series or simultaneously, cause a breakdown of the control system. To
ensure that information about the system breakdown is understood and utilized to identify effective corrective
actions, an incident investigation process is used. The OHS management system defines the parameters and
processes to obtain information and learn lessons from an incident.

An incident reporting and investigation process requires a policy that identifies responsibilities and
accountabilities, forms, and training programs on incident investigation techniques that direct the investigator to
identify root causes of the incident and formulate recommendations to correct any deficiencies that contributed to
the incident. For greater effectiveness, the policy should require the reporting and investigation of all incidents
resulting in injury or property loss, plus all work-related illnesses and near miss incidents. In addition, like other
health and safety processes, incident investigation protocols require a mechanism to ensure that follow-up
corrective actions occur and that lessons can be learned through the communication of the investigation findings.
As per the audit process, auditors will review completed investigation reports to determine the quality of
investigations and the ability to effectively identify the root causes associated with the incidents.

Employee Competency
Employees who are competent to perform the tasks are less likely to be injured than those who are not prepared.
OHS management systems must address the issue of employee qualifications, orientation and training to ensure
employees are able to perform their work safely. Generally in this element, the Human Resources system must
ensure that qualified employees are hired for the positions in the company. This requires an understanding of
what qualifications are required, including educational qualifications, current certifications, trade “tickets”, or
physical requirements. These requirements should be documented for each specific position and verified for each
new employee.

Employee orientation should include an understanding of basic safety rights and responsibilities, as well as
information about company safety policies and procedures. Audit instruments may specify information required in
new hire orientation. Examples include the process to report hazards, emergency response procedures including
location of muster points, and incident reporting requirements. Orientation is an excellent opportunity to
showcase the importance and value of OHS in the organization.
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On-going training is also important to ensure that employees are kept current with health and safety issues and
procedures in the workplace.

Manager education is another critical process, as management has ultimate responsibility for health and safety in
the workplace. An effective health and safety management system includes manager education to ensure
managers have the tools necessary to assume this responsibility.

Auditors usually must verify orientation and training by reviewing training materials and attendance lists to ensure
that skill and safety related training is provided to all employees. In addition to general orientation, job-specific
health and safety training is often provided when the employee starts work. Auditors should verify that employees
obtain critical safety information before starting regular work.

Emergency Preparedness
Another factor in injury prevention is minimizing the impact of emergencies in the workplace. Emergency
situations with significant risk may have serious consequences, including property damage and injury or illness to
employees, customers, visitors, and contractors. Being prepared for emergencies enables quick reaction to
protect those who may be impacted by the situation. OHS management systems provide for the identification of
all potential emergencies that may occur at the worksite. This is followed by a careful development of a response
plan, with the identification of those responsible for each aspect of the response. Communication and practice
(drills) of the response are important components of the emergency response plan. Follow-up to all drills and
incidents enables lessons learned to contribute to improvements. Auditors often verify that first aid plans
(including the number of trained first aid providers) and equipment are appropriate and that a sufficient number of
emergency response plan drills/exercises are conducted and evaluated for effectiveness.

In organizations where shift work occurs, the auditor must verify that those working all shifts are aware of the
emergency response plans, have opportunities to practice responses (drills) and that adequate numbers of
trained first aiders are available.

System Administration and Quality Control


Responsibilities for the ongoing maintenance of the system are identified in the management system. Employee
participation is a desirable factor and communication is a critical component. Occupational Health and Safety
committees play a significant role in the administration or oversight of the system in many jurisdictions, with
legislated requirements regarding the membership of the committees, roles and responsibilities of the committee
and required training for committee members. Quality control efforts must review all program aspects and
outcomes and provide information for the continuous evolution/improvement of the health and safety
management system.

Management Systems are often described as a continuous improvement cycle of activities, which includes the
setting of standards, the identification of gaps between the current status and what the standards prescribe, the
planning and implementation of work needed to close that gap, the measurement of program success, and the
review/revision of standards. The audit process functions to address two major components of this cycle – the
identification of gaps and the measurement of program effectiveness.
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This is depicted in a well-established PLAN-DO-CHECK-ACT diagram:

Set/Revise
Standard
Measure
effectiveness Identify
Gaps

Implement Action Develop


Plan Action Plan

Audit function

Figure 1

Audit instruments
In recent years, the evaluation of health and safety management systems has been demonstrated to be an
effective tool to improve health and safety in the workplace. As a result, there has been increased interest in both
developing audit instruments appropriate to the various industries and in standardizing the audit instruments to
enable more accurate benchmarking. In addition, the evolving merger of the environment and health and safety
functions in many companies has led to a desire to use a common audit process, and perhaps a common audit
instrument, to evaluate both domains. OHSAS 18001, the US ANSI Z10 and the Canadian CSA Z1000 all utilize a
Plan-Do-Check-Act approach introduced in auditing by the environmental ISO 9000 and 14000 audits.

Audit instruments are tools designed to guide the auditor towards a systematic, standardized review of a
company’s health and safety management system. There is a broad range of instruments available to the
company being audited. The desired outcome of the audit often dictates the content of the questions and the
required validation methods. Some of the desired audit outcomes are listed in the table below.

Possible Audit Report Outcomes

 List of conformances/non-conformances
 Points awarded as scores on audit elements
 Recommendations for program improvement
 Gap Analysis comparing status to standards
 Compliance verification
 Due diligence report

Table 8
Specific types of audits are conducted based on a company’s desired outcomes. In some cases, certification
bodies may prescribe a specific format and report contents that the auditor must abide by. Auditors may be
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required to be certified to use specific audit instruments. Most often, the company selects the standards and the
audit instrument to be used, with the guidance of the auditor. There is considerable similarity in the OHS
Management Systems standards currently in use.

In 2006, the Canadian Standards Association published CSA Z1000, which is the first consensus-based OHS
Management System Standard in Canada. The standard is based on the Internal Responsibility System premise
that all workplace parties have accountabilities and must work together to improve health and safety in the
workplace.

Key topics covered in CSA Z1000


 Commitment and leadership
 Worker participation
 Occupational health and safety policy
 Legal and other requirements
 Hazard and risk identification and assessment
 Objectives and targets
 Controls
 Emergency preparedness
 Competence and training
 Contractor safety and procurement
 Change management
 Incident investigation and analysis
 Preventive and corrective action
 Planning
 Monitoring, measurement and review
 Documentation
 Implementation
 Audits

In 2005, the American National Standards Institute (ANSI) published ANSI Z10, which endorsed the principles
and tool used by OSHA (Voluntary Protection Program).

Key topics covered in ANSI Z10


 Management leadership and employee participation
 Policy
 Accountability
 Initial and ongoing reviews
 Assessment and prioritization
 Implementation plans
 Allocation of resources
 Hierarchy of controls
 Change management
 Procurement and contractors
 Emergency preparedness
 Education, training and communication
 Documentation and record control
 Incident investigation
 Monitoring and measurement
 Corrective and preventive actions
 Feedback, review and follow-up
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Both the CSA Z1000 and the ANSI Z10 are standards for health and safety management systems. They are not
audit instruments, but rather can be the basis for the development of instruments.

OHSAS 18001 is an audit specification document, not a standard. It provides details about what auditors should
be looking for in assessing OHS Management System Elements.

Core OHS Management System elements described in OHSAS 18001


 OHS policy
 Hazard identification, risk assessment and control
 Legal requirements
 OHS objectives
 OHS roles, responsibilities and accountabilities
 Training and communication
 Documents and record control
 Emergency response
 Performance measurement and monitoring
 Accident and incident investigation and corrective action implementation
 Audit program
 Management review

Two general classes of audit instruments are used – the scored instruments and the un-scored instruments.
Within these two classes, audit instruments range in complexity from simple worksheets with a checklist of items
to review to complex forms with detailed verification procedures for each question. Companies with continuous
improvement processes often migrate from simple audit instruments to more demanding complex instruments
over the evolution of their health and safety programs.

Benefits of Scored Instruments

 Enable the tracking and measuring of program improvements


 Enable benchmarking among company facilities or branches
 Focus on results rather than auditor style
 Facilitate objectivity
 May require less professional judgment
 Meet the requirement for some certifications

Table 9

Benefits on Un-scored Instruments

 Give auditors freedom to address systemic issues


 Meet the requirement for some certifications
 Allow for auditor-determined weighting of importance of items
 Do not specify the numbers of interviews required
 Do not result in a focus on “scores”, but rather on findings and recommendations

Table 10
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Overview of the Audit Process


The audit process constitutes a formal, standardized approach to evaluating the effectiveness of the H&S
management system. Each protocol includes specific instructions that must be closely followed. All audit
instruments require that certain information be verified using one or more of three validation methods –
documentation, interviews and observations in the workplace.

The audit process is frequently broken down into three phases – the work done before the audit on-site activities
start, the on-site activities, and the work done after the on-site activities have been completed. These are often
referred to as pre-audit, audit, and post-audit phases, although they are all included in the term “audit”.

The following diagram depicts the activities conducted in the various audit phases:

Auditor Employer
Activities Activities

Requests
Writes proposal
proposal

Initial meeting/
Selects auditor
clarification of issues PRE-
AUDIT
Writes contract
Writes contract

Communicates
Develops audit plan
with staff

Pre-audit meeting
Pre-audit meeting

Provides
On-site validation –
Documentation,
document review,
interviews, ON-SITE Arranges
interviews and
observation tours (AUDIT) tours

Post audit
Post-audit debriefing
debriefing

Analyzes finding,
complete report POST- Receives report
AUDIT
Audit
Audit presentation
presentation

Implements
action plan

Figure 2
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Pre-audit Activities
As shown in the diagram above, considerable activity occurs before the on-site phase of the audit. When an audit
is requested, understanding the reason a company wants to have an audit conducted impacts the auditor’s
decision about whether to conduct the audit. Ideally audits are conducted for constructive purposes, including
establishing a performance baseline, benchmarking between company branches, identifying issues that have
impacted safety performance with a view to correcting deficiencies, measuring improvement, and communicating
the importance of health and safety to employees. When an employer seeks an audit as a result of a compliance
order, to be eligible to bid on projects and contracts, or strictly to obtain a specific score to profit from financial
incentives, the auditor must ensure a clear understanding of the audit process and value. Auditors may be placed
under substantial pressure to give a “passing mark” to an employer, and must avoid conducting an audit in which
their objectivity may be compromised.

The discussion that takes place before the auditor is selected and elects to perform the audit should be directed
towards understanding the motivation for having the audit performed, the scope of the audit, and the
appropriateness of the auditor’s qualifications to conduct the audit requested. The following issues should be
clarified prior to the auditor’s acceptance of the contract:

 The employer’s motivation for requesting an audit


 The industry/products/processes involved
 The number and geographical distribution of facilities or worksites
 The number of employees
 The hours of operation
 Seasonal difference in staff and work
 Completion date required
 OHS Management System standard and audit instrument to be used
 Any potential disruptions to the audit process (strikes, vacations, etc.)

The auditor should be familiar with the employer’s industry and be certified (if required) to use the audit instrument
desired. Auditors are usually trained on the use of specific audit instruments to help address inter-auditor
consistency. Auditor training may be intensive and extensive, or may be a brief refresher course given
periodically. It is particularly critical that, if certification based on the audit results is desired, the auditor must be
qualified and in good standing to utilize the audit instrument.

In addition, the auditor must be available to conduct the size and scope of audit within the requested timeframe,
and be comfortable that he or she will be able to conduct the audit objectively prior to accepting the contract.

If the company is requesting its first audit, the auditor is best advised to discuss the audit process and ensure the
company understands what is required.

After initial discussion between the company representative and the auditor and the decision is made to proceed
with the audit, the auditor should confirm what was discussed in a proposal letter. The key components of an
audit proposal letter include:

 Introduction
 Identification of health and safety issues of concern to the company
 Choice of audit instrument to be used
 Scope of audit (facilities to be audited, etc.)
 Audit process and schedule
 Sampling strategy
 Audit team (if applicable)
 Administrative details – space required, access, any orientation required, any personal protective
equipment required
 Deliverables, including the format, process and timing of report submissions.
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 Fee structure

This letter may serve as the contract if there is a space for signatures and dates. In addition to the contract,
auditors may be required to sign non-disclosure and confidentiality statements.

In some cases, an employer may not be sure the organization is ready to conduct its first audit. An employer may
request that an auditor provide an early warning if it is very clear that the organization is not ready. Some auditors
offer a “readiness assessment” prior to the audit. A readiness assessment consists of asking questions to
ascertain the level of documentation available that could support the audit requirements. It is not in any way a
“pre-audit”, as the quality and quantity of documentation is not assessed, nor is there any confirming observation
or interviewing done. A readiness assessment does not imply that audit standards will be met, only that there is
documentation related to the specific requirements. A readiness assessment is not usually conducted for an
employer that has already had an audit conducted.

Preparing for the audit


Once the decision is made to conduct the audit, the auditor must determine if an audit team is required.
Generally, if the audit can be conducted with on-site activities of 10 days or less, a single auditor may be
sufficient. If the completion time for a single auditor would be more than two weeks of on-site activities, it would be
wise to consider obtaining assistance. As an audit is considered a “snapshot” of the health and safety
management system, it should not be conducted over a lengthy period of time where the possibility exists that
significant changes occur while the on-site audit activities are in progress.

The auditor is responsible for developing the audit plan, and ensuring all aspects of the audit process are
followed. When an audit team is involved, coordination of the auditors is vital to ensure the most efficient use of
resources and to avoid confusion for the audited company.

The responsibilities of the auditor(s) include the following:

 Communicate and explain audit requirements to the company’s management. This is usually done in the
initial contract discussions, confirmed in writing, and re-stated at the pre-audit meeting.
 Comply with all audit instrument requirements. These vary by instrument but usually include a required
sampling strategy, compliance with verification methods and scoring, documents required for submission,
and format of the audit report.
 Document all observations, verifying effectiveness of any corrective action taken as a result of incident
investigations, inspections or hazard reports. Specific observation requirements are supplied in some
audit instruments. Effort should be made to avoid random comments during the observation tours.
 Report results and provide recommendations. This is also a requirement of the audit instrument. It should
be noted that audit instruments vary in their approach towards recommendations. Some require a specific
recommendation for every item in the audit that does not receive 100% of the possible marks, others
expect the auditor to determine general themes and choose a reasonable number of recommendations.
Recommendations are always expected to be feasible and within the scope of the audit. Some audit
instruments require that findings are presented as referenced observations of conformances or non-
conformances and do not permit recommendations.
 Conduct themselves professionally and avoid conflict of interest situations.
 Ensure the audit plan is carried out effectively. This usually requires planning and the development of
information collection tools to ensure that time is spent efficiently.
 Stay within the scope of the audit. The scope of the audit refers to what is actually being evaluated, both
in terms of aspects of the company, as well as specific elements being audited. The auditor is sometimes
tempted to comment on aspects of health and safety that are not being assessed with the audit
instrument. These are considered “out of scope” and should be avoided.
 Report imminent danger situations immediately. Health and safety professionals conducting audits
occasionally find themselves in a situation where they are observing behaviours or conditions that pose
an immediate danger to workers or others. It is their professional responsibility to report the situation or
stop the work. Auditors often identify this issue in their contract discussions to ensure the employer
understands and accepts this position.
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 Maintain objectivity.
 Collect and analyze sufficient data. Though an audit instrument often defines the amount of “sampling” to
be done (i.e. the number of documents to review, the number of people to interview), auditors sometimes
are required to increase the data reviewed to ensure that they are correct in their evaluation. This is
particularly the case when the data appears to be contradictory.

Assisting the company with communications


At times, companies experiencing their first audit do not effectively communicate the audit objectives and process
to employees. This may result in a higher anxiety level related to misunderstandings about the interview process.
It is not uncommon in a first audit for employees to perceive that the interviews are “tests” of their health and
safety awareness or knowledge, and some worry about “passing”. Experienced auditors will address the
communication issues with the company contact and may provide the company with template notices or letters
that the company may customize for use prior to the audit. In addition to providing valuable information about the
audit process, a notice to employees from senior management serves to demonstrate support for the audit
process and encourage cooperation from all staff.

Early communications can also alleviate problems that may arise related to confidential information. Some
employers are reluctant to allow auditors to review employee files that may contain training records or disciplinary
notes. Yet these may be required verifications. It can be advantageous to emphasize the confidentiality
agreements that have been signed and to find ways to minimize the impact of these activities. For example,
having a human resources person with the auditor often reduces the anxiety that may accompany the auditor
review of employee information.

The Audit Plan


An audit plan is a written outline defining the parameters of the audit. It is usually developed by the auditor and
approved by both the employer and the auditor. The plan sets forth responsibilities, expected activities and
timeframes, but should remain flexible enough to be modified as a result of information gathered during the audit.

The audit plan includes the following parameters:

 Audit scope and objectives


 Identified employer contact person
 Identified audit team members (if applicable)
 Identification of audit instrument to be used
 List of required documentation for review
 Date, time, location of on-site audit activities
 Dates and durations of all audit activities
 Statements of confidentiality
 Identification of deliverables – date, media, number of copies, and format of report delivery

Auditors are responsible for ensuring that all audit activities occur on schedule, even if this means working late or
reassigning audit team members. The auditors must take into account and perform audit verifications for all shifts.
There may be many challenges related to scheduling, particularly the scheduling of interviews. The auditor would
be wise to allow for some flexibility in the schedule, as there may be some “no shows” for interviews, incidents or
situations may prevent the observation tour from occurring as planned, and documentation may not be available
(particularly if in electronic format).

Auditor Preparatory Tools


One of the most significant challenges faced by auditors is the organization of all the data that is being collected.
In many cases, more than one validation method is used to assess the status of compliance to various standards.
Assembling interview notes in a meaningful manner becomes more complicated with increased numbers of
interviews. To ensure the most efficient collection of data, the auditor develops tools to assist in all phases of the
information gathering.
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Sampling Tools for Interviews


The ideal way for an auditor to be certain that he or she is accurately assessing the status of the health and safety
management system is to interview all employees and review all documentation pertaining to the system.
However, this is not practical for most companies. Therefore the auditor must take a sample of available data – a
number of people to interview, a number of documents to review, a number of places to visit – that would be an
accurate representation of the whole company. The question faced by auditors is “how large a sample do I need
to be convinced that this is an accurate representation of the whole company?” Many audit instruments or audit
certification organizations have developed sampling tables that suggest or require “representative” numbers of
interviews or documents. These are usually set as minimum standards; however, the greater the discrepancy in
the information collected or the greater diversity of work being done, the larger the sampling size that will be
required to be confident that a true assessment can be made. The auditor should ask himself this question in
determining the correct sampling size – Is this sample size sufficient to give me the confidence that I am correctly
perceiving an accurate picture of the health and safety management system? The auditor should not rely
completely on the minimum sample size required on audit sampling tables provided by certifying bodies, as this
may be inadequate in providing the auditor with that sense of confidence.

Most sampling for interviews is done using a semi-randomized technique. True randomization means that every
person has an equal likelihood of being selected for an interview. This is not appropriate for audit interviews, as
there are specific individuals who will be required to be interviewed. In a semi-randomized technique, a
stratification of employees by level is first done, as most audit instruments require interviews with senior
managers, frontline managers and employees, as well as contractors. With this list, specific individuals may be
required for interviews, such as the company president, a human resources person responsible for training, a
purchasing department manager, etc. When there are many persons occupying the same level/occupation, a
random selection can be made. The random selection can be performed in several ways. Figure 3 describes
three methods of random sampling.
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Random Selection Process – 3 examples of methods

Task – Randomly select 15 assembly line workers from a total of 90 for interviews

Method 1:
List all 90 employees alphabetically and choose every 6th name on the list

Method 2:
Put all names on papers in a hat and choose 15

Method 3:
Number each employee 1-90; Use a random number generator (available in statistics books
or on the internet – search for random number generators)

Figure 3
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The auditor also interviews a “targeted” number of employees who are able to provide insight on specific topics.
For example, to assess the current new hire orientation program, the auditor will need to speak with employees
who have been hired within the last year. To validate information about communication of incident investigation
information, the auditor may wish to interview employees who have been involved in an incident. Normally, the
auditor is responsible for selecting those to be interviewed, usually with the assistance of the company contact
person.

Audit Communication Tools


Timely communication about the audit strongly impacts the success of the on-site activities. Auditors can assist
the company in communicating the purpose and activities of the audit by providing template letters that the
company can customize. When employees understand how interviews are conducted, the commitment to
confidentiality and the fact that there are “no right or wrong answers”, they are much less anxious about the
interview process and more willing to participate.

The pre-audit and post-audit debriefing meetings are also important tools for communicating about the audit. The
auditor who recognizes this prepares carefully for these meetings.

Field note tools


Comprehensive field notes must justify all evaluation comments or scores. These notes are the summation of all
information collected about a certain topic, including the tally of interview responses or documents reviewed or
observations that support or do not support compliance to the standards.

The format for note taking should be determined before the on-site activities take place. Worksheets for easy use
should be developed and all team members should utilize the same format for taking notes during interviews,
document review and observation tours.

Worksheets should be developed that will assist the auditor in integrating information collected through interviews,
document review and observation. These worksheets should also provide a mechanism to indicate what follow-up
audit activities may be necessary to validate the various aspects/elements audited.

Some electronic instruments have very specific formats for documenting field notes, and some certifying bodies
have specific requirements as to the format and terminology that should be used in field notes.

Electronic tools
In recent years, there has been a move to develop and use electronic audit tools. Some of these are useful for
data collection, including checklists that are adapted to handheld electronic devices. There are also several audit
instrument software packages associated with specific instruments that assist the auditor in collecting and
organizing data, scoring elements, and writing recommendations. While there are many benefits to using these
and they may well prove to be extremely popular in the future, the auditor should not rely exclusively on these
devices and programs to produce the audit report. Professional judgment is a critical skill in auditing and a “cookie
cutter” approach may stifle individuality and style in the audit report. With some electronic instruments, common
errors are reduced. For example, instruments that automatically calculate scores or ensure that the correct
validation methods are used can be very helpful. Electronic instruments often are beneficial in amalgamating
results from multiple auditors in a team.

Preparing to go on-site
Once the tools that the auditor will use during the audit are completed, the auditor also ensures that all required
equipment is brought to the site. This may include personal protective equipment, specific legislation that will be
referenced, all worksheets and checklists that have been created, the interview schedule, a watch or clock, note
paper, and a calculator. In addition, the auditor may find it useful to bring a computer and a camera. In some
companies, the auditor is considered a “contractor”; in others, a “visitor.” The auditor should note what orientation
is provided for him or her (or the audit team) and what rules must be followed, as this is a good indication of how
contractor and visitor safety is managed.
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Audit Team Communication


There are many advantages to using a team to conduct an audit. The availability of team members with varied
backgrounds and experience can ensure that an objective understanding of the health and safety management
system occurs and can strengthen the thought and discussion processes in the developing of recommendations.
The time required to complete an audit will be reduced with an audit team. However, the use of an audit team also
poses significant challenges. Communication must occur on a regular basis to ensure that there is no redundancy
of work, that issues that surface are dealt with quickly, and that trends that may require additional data collection
or communication with company officials are discussed. The audit team leader is responsible for the coordination
of all audit activities and for ensuring a good communication system is in place for the auditors. Specific
instructions to team members about the format of notes will facilitate the report writing. Requiring auditors to input
data on a daily basis into prepared worksheets or electronic audit instruments will provide the lead auditor with the
overview of the audit as it progresses, and provide an opportunity to intervene early if necessary. Team “check-in”
points or regular meetings are also useful for keeping the audit process on-track and identifying and correcting
any logistics problems before they seriously impact the process.

The “kick-off” Meeting


The formal introduction of the company to the audit process first occurs at an opening meeting (the “kick-off
meeting”) usually on the first day the auditors are on site. This meeting establishes the tone of the audit and
contributes to ensuring the cooperation of company personnel. The company usually selects those invited to
attend the meeting. In addition to the audit team, this group may include senior management, frontline managers,
internal health and safety staff, representatives of frontline workers (including unions), and/or health and safety
committee members. The meeting serves to initiate the on-site audit activities, familiarize those attending with the
audit instrument and activity timetable, introduce the auditor(s), and provide an opportunity for participants to have
questions answered. The opening meeting is approximately 30 minutes to 90 minutes long, depending on the
client’s level of familiarity with the audit process. At this point, employees and managers should already be
prepared for the audit; they should have received communication, been scheduled for interviews, and submitted
required documentation for review. The opening meeting presents an opportunity to respond to any questions and
clarify any issues. The auditor can often gauge the level of support for the audit process as well as the
organization’s communication strategy and culture in the opening meeting. A typical opening meeting agenda is
shown in Table 11, below:

Opening Meeting Agenda

1. Introductions
2. Purpose and scope of audit
3. Audit instrument – major areas covered
4. Validation methods
Documentation
Interviews
Observation
5. Confidentiality and privacy issues
6. Imminent danger and other tour issues
7. Audit schedule
8. Audit deliverables
9. Questions and answers

Table 11
As with any formal meetings, success depends upon good planning and preparation. If there is a formal
presentation, the auditor(s) should prepare slides that follow the agenda, and should anticipate potential
questions and prepare responses. Often a discussion with the company contact person will provide information
about the attendees at the meeting that will enable the auditor(s) to address specific issues of interest to them.
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Attendees may ask a variety of questions at the opening meeting. The types of questions asked are often a
reflection of the level of awareness about the auditing process and may sometimes reflect individual agendas.

Examples of questions/comments an auditor should be prepared to address

1. Why is it necessary to observe various sites? Isn’t one site visit enough since we all do the same thing?
The auditor is auditing the organization as a whole. In many cases, environmental conditions at sites may
vary considerably. Site management may differ in implementing policies and procedures.
2. Why do you have to speak to our contractors? They have their own safety programs. A health and safety
management system works to ensure that all aspects of health and safety are managed. Auditors are not
assessing the contractors’ safety programs during the audit, but are verifying that there are adequate
safety requirements provided by the employer’s contractor safety program.
3. What if someone has a bone to pick with management and fabricates stories? Auditors are trained to
interview an adequate number of people to feel confident that they see a true picture of the organization.
4. What if our employees do not speak English well? It may be necessary in some cases to have an
interpreter present.
5. Our senior management team is very busy and doesn’t have time for interviews. Management
commitment is the underlying element in health and safety management systems audits; it is important for
senior management to demonstrate and reinforce that commitment by participating in audit interviews.
6. What if we fail the audit? Audits provide recommendations for improvement in each audit element. A
company that does not pass its audit should be encouraged to develop an action plan to implement the
recommendations. In some cases, when a company narrowly misses the cut-off for a “pass”, there may
be processes in place for a limited scope audit. A limited scope audit addresses the element(s) that did
not achieve a “pass”.
7. What if we pass the audit – what are the next steps? It is important for a company that has passed its
audit to continue improving its management system. This can be done by implementing audit
recommendations. When a company attains high results on several audits, it may want to consider other
audit instruments with a greater scope.
8. What type of reward will we receive if we pass the audit? This depends on the reason for the audit and
the type of audit. A passed compliance audit may provide validation that required processes are in place.
An audit may lead to a “Certificate of Recognition” or similar rewards; these may be useful in advertising
for the company, in qualifying to submit a bid for work, or in monetary rewards depending upon the type
of audit.

Documentation
One of the three critical validation processes used in health and safety system auditing is the review of company
documentation. Documents provide an evidence trail that may prove that a company is or is not duly diligent in
protecting the health and safety of workers. For all elements of a health and safety system that are evaluated by
auditing, certain basic documents are required to describe the system. Policies, procedures, and guidelines are
reviewed to determine what the company’s expectations are. As a validation method, documents are reviewed to
ensure they contain critical elements and to help identify specific aspects of the system that will be validated by
other methods. For example, if a policy identifies that managers are required to correct deficiencies identified in
incident investigation reports, the auditor will review completed investigation reports, noting the corrective action
required and will then verify that the corrective action occurred by observation. In a similar vein, if the policy states
that all employees must wear eye protection, this is validated by interviewing employees and also by observing
that they do indeed wear the required personal protective equipment.

Two major classifications of documents are reviewed in the audit. These are “directive documents” that describe
what should be done and how it should be done, and “operational records” that document what actually occurs in
the company. This is an important distinction because it enables an auditor to distinguish between the company’s
intent and its practice. Companies often develop good policies, procedures and guidelines that would effectively
create and maintain a healthy and safe workplace, but actual practices may be quite different from those required
in the directive documents. This gap in the application of the directive documents sometimes leads to unsafe
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conditions and actions. Examples of related directive documents and operational records are provided in the
following table:

DIRECTIVE DOCUMENTS OPERATIONAL REPORTS

Occupational/Environmental health and safety policy

Statement of Management Commitment  Minutes from management meetings


 Review of management communiqués about health
and safety
 Current goals and objectives
 Bulletins/ newsletters from management
 Data/reports presented to senior management

Roles and responsibilities statements  Job descriptions


 Performance evaluations

Hazard identification policies and procedures  Completed hazard assessment forms


 Attendance lists for hazard assessment training
 Hazard reports

Hazard control policies and procedures  Maintenance records for engineering controls
 Training records for personal protective equipment
use and maintenance
 Respirator fit-testing records
 Safe Operating Procedures
 Hazard report follow-up
 Occupational hygiene reports

Health and Safety Committee Terms of Reference  Minutes of meetings


 Attendance lists from meetings
 Follow-up to resolutions or issues discussed

Orientation and training requirements  Orientation material and checklists


 Orientation attendance lists
 Training records
 Completed examinations or tests

Hiring policies and procedures  Completed checklists


 Pre-placement health assessment records
 Criminal records checks

Inspection policy, procedures and forms  Completed inspection reports


 Follow-up reports
 Inspection training records

Incident reporting and investigation procedures and  Completed incident investigation reports
forms  Follow-up reports for correction of deficiencies
 Incident investigation training records

Emergency response plans  Current lists of trained First Aiders


 Emergency response drill reports
 Emergency response records

Table 12
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The company safety manual is often a compilation of the company’s directive documents and sets forth the
expectations for how health and safety should be managed. Directive documents are frequently found on the
company website. How a company implements and enforces the policies and procedures is assessed by
reviewing the operational records. Operational records may be maintained in many different locations, both
centrally and in specific departments. The auditor usually supplies a list of required documentation to the
company contact, who gathers it from various sources for the auditor. Often the company contact attempts to
select the specific records for the auditor. An auditor may be presented with “examples” of completed hazard
assessment or inspection of incident investigation documents, and has no way to validate that these are
representative “samples”. In addition, a few samples rarely suffices to validate the quality of a process overall,
especially in a larger organization. The auditor must make the sampling requirements known to the company
contact, and be very clear on the number and type of documents to be provided to ensure that a representative
sample is examined as part of the documentation reviews.

At times, the auditor will need to review the operational reports at the specific department. For example, training
records may be maintained by the department manager or maintained centrally; MSDS binders are usually kept at
the department level; hiring and orientation records may be housed in the Human Resources department or by
the department manager.

In the increasingly common situation where records are maintained solely electronically, the auditor often must
have access to the company’s internal website and record files. In this case, the auditor should identify required
types of documentation and request access to the electronic files. Usually, a company representative will assist
the auditor by guiding him or her through the electronic documentation system and allowing access to individual
files. The auditor should ensure that field notes are complete, as he or she may not have the opportunity to revisit
the electronic files.

Conducting the Document Review


Many auditors choose to conduct the document review at the initial stage of data collection. This enables the
auditor to make notes for required follow-up to verify that corrective action has taken place, and allows for a more
efficiently conducted audit. There is no required format for the document review process. The critical task is to
ensure that sufficient documentation is reviewed so that the auditor is confident that the documentation is
representative and reflects the company’s health and safety system accurately. Auditors may choose to schedule
the document review to occur all at once, or in segments over the course of on-site activities,

Where significant numbers of records exist (as in incident reports, inspection reports, etc.) the auditor must use a
sampling strategy to determine which specific documents will be reviewed.

These same tools as those previously discussed for interview selection can be utilized when there are large
numbers of documents to review. All available reports may be given a number, and the auditor can select a
sample using a random sampling technique. In a very large audit, the auditor may randomly select departments
from which to review records, such as training records or inspection reports. An additional technique for selecting
documents is called “chronological blocks”. For this technique, documents created in a specific time frame are
reviewed. For example, if a company has 100 incident reports, the auditor may choose to review all incident
reports for January, April, July, and October. The larger the number of documents, the smaller the time periods
that are chosen. When selecting documents for review, the auditor should include records over a period of time,
usually a year, to enable a review of the follow-up that occurred. If an audit is conducted in October, for example,
reviewing incident investigation or workplace inspection reports from earlier in the year allows the auditor to verify
the length of time taken for corrective actions to be implemented.

Even if the document review is conducted as the first step in the on-site activities, auditors often request that the
documentation remain available throughout the course of the on-site activities. This allows the auditor to go back
and verify specific issues that may be brought up in the course of interviews or observations.

For team audits, it is usually most efficient to have the entire team review the documentation, as the
understanding of the system as designed and implemented enables more effective interviews and observation
tours. Some audit teams assign responsibilities for specific audit elements to individual auditors. Though all audit
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team members review the documentation, the individual auditors may be responsible for validating the specific
elements they are assigned and writing the relevant field notes for those elements.

As the documentation is reviewed, the auditor should maintain good notes that will help justify scores or findings.

A closer look at the documents


When reviewing documents, the following aspects should be considered:

What to look for in reviewing documents

 The quality and contents of the documents


 The date the document was created and/or reviewed
 Time/frequency requirements in documents
 The communication surrounding the document
 The life cycle or travel path
 The specificity of documents

Table 13
Quality and contents
In many audit instruments, specific elements are required to be present in the documents. For example, an audit
instrument may specify that incident investigation policies and procedures require the identification of the root
cause of incidents; worksite inspection policies include risk classification and follow-up process; emergency
response plans include emergency contact information, and health and safety policies be signed by the current
senior operating officer. Auditors must follow the audit instructions to ensure that they can justify their evaluation
of the documents.

As the auditor reviews the documentation, it is useful to make lists of corrective action items that were identified in
inspection reports and incident investigations. This list could then be used during the observation tour to verify
that corrective action occurred.

Currency of documents
The documents should be current. In many companies, directive documents such as policies remain in effect for a
long time, while procedures may change more frequently to reflect internal processes. A process should be in
place for periodic review of policies and procedures. When there is no “expiry” date for policies and procedures,
the auditor considers whether the document is still applicable. In the case of general polices, a change in senior
management signals the need for a review and reaffirmation of the policy contents.

Time and frequency requirements


In many policies and procedures, specific timeframes or frequency requirements are specified. Examples include
requirements for worksite inspections at a specified frequency, an allocated time frame for correction of
deficiencies, a specified number or frequency of health and safety committee meetings, a specified frequency of
emergency response drills, etc. The auditor notes these requirements in the directive documents, and verifies that
they are met in the operational records.

Communication
Effective communication of policies and procedures helps to ensure that employees are aware of them. The
auditor reviews how the communication occurs and the availability of the documents to employees. This may
include the use of the company’s internal web site.

Life cycle of documents


The life cycle or travel path of documents refers to how documents originate, where they go and what is done with
them from their creation until they are filed or considered complete. For many documents, the travel path is
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lengthy and sometimes complex. The following hypothetical example (Table 14) illustrates the life cycle of an
incident report/investigation form, as required by Company XYZ policy.

Activity Action by: Date

Incident occurs; incident report filed Employee June 1, 20XX


with supervisor

Incident investigated, corrective Supervisor June 2, 20XX


actions recommended

Copy sent to OHS Supervisor June 3, 20XX

OHS reviews and signs off OHS advisor June 4, 20XX

Corrective action completed Supervisor, others as required June 10, 200XX

Communication with, sign off by Supervisor, Employee June 10, 20XX


employee

Copy sent to Manager Supervisor or OHS June 10, 20XX

Manager sign-off Manager June 11, 20XX

Report filed Supervisor, OHS June 12, 20XX

Table 14

Document specificity
When reviewing directive documents, auditors sometimes encounter very detailed policies, procedures and
manuals that appear to be generic “off-the shelf” documents. With so many commercial suppliers of programs
available, many companies have purchased programs to meet their needs and have customized these ‘model
documents” to avoid the effort required developing company specific programs. Benefits of accessing these
prepared materials include the avoidance of having to “start from scratch” and the confidence that legal
requirements will be addressed. However, these “off-the-shelf” programs are sometimes not customized by the
company being audited, and, as a result, are not seen as pertinent to the company, which may result in workers
not reading or following them. In fact, some of these commercially available programs are placed in binders that
are kept on shelves or filing cabinets and brought out only during the audit. The auditor usually can identify when
this is the situation by reviewing the contents of these documents to see if there has been any customization to
make them applicable to the company. For example, if a company’s safety manual contains policies for confined
space entry or forklift safety and there are no confined spaces or forklifts on the sites, the auditor may suspect
that an “off-the-shelf” program has not been appropriately customized.

The auditor should keep an open mind when requesting or reviewing documents. A flexible approach is
necessary, as a company may use different terminology than the audit instrument uses. For example, some
companies do not have “policies”, but rather have company “standards” that fulfill the same requirement. Another
example is the use of the term “inspection”. Some companies may refer to inspections as “safety checks” or use
other terms. The auditor should keep in mind the intent of the question.

Interviews
Validating the health and safety system particulars relies heavily on interviewing all levels of staff and employees,
as well as contractors who may be working on site. This reliance on interviews is one of the key factors
differentiating the health and safety management system audits from the environmental management system
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audits. One major reason for this is that the impact of an environmental management system is seen to be the
environment or legislative compliance to environmental laws, whereas the impact of a health and safety
management system is on the health and safety of those who work in the company.

With established management commitment to the health and safety system and good communication processes,
the interviewing process should parallel and validate the document review and observation processes. If, on the
other hand, documentation defines a process that has not actually been implemented, interviews and
observations are likely to show disparate results from the documentation review.

The following table lists the key outcomes of interviews as part of the audit process.

Outcomes of the Interview Process

 Confirmed validation of documentation and observations


 Compliance with audit instructions regarding validation methods
 Provision of a human perspective and verbal account of the system
 Representative sampling providing information quickly
 Evidence of system impacts on employees

Table 15

Interviewing Skills
The skilled auditor is an effective communicator. Audits require interviews with all levels of staff and the auditor is
responsible for facilitating the discussion with each interviewee in such a manner that the interviewee is able to
speak frankly and openly about the health and safety management system and does not feel “interrogated” or
pressured to respond in specific ways.

The auditor recognizes that different personalities come into play in an organization, and that roles and
experiences influence how the interviewees respond. Language and cultural considerations also impact the
interview process, and the skilled auditor develops a communication style that will be flexible and adapt to the
individual circumstances presented in the interviews.

The preparation or lack of preparation by senior management also impacts the perception of the interview
process even before it begins. It is not uncommon to discover that employees have been told little about the audit
purpose and process and appear at the interviews in a somewhat anxious state, fearing that they might “fail” what
they perceive to be a test of their safety knowledge. On the other end of the scale, employees may have been
coached as to what to say in the interviews. When interviewees arrive for interviews with the same Questions &
Answers printed out, it is reasonable to assume that the employees are being “coached” in their answers. The
auditor uses communication skills to put the interviewees at ease and obtain information that reflects the
individual’s true experience with the health and safety program and management system.

Interview questions
Audit instruments vary in the provision of interview questions. Many instruments leave the formulation of
questions up to the auditor, with the understanding that the auditor must ask questions that will enable him or her
to validate specific audit elements. Some instruments provide a list of questions to ask each level of employee in
the organization and cross-reference the questions to the specific audit elements. While this appears to greatly
assist the auditor, it sometimes has the opposite effect, in that auditors (particularly inexperienced auditors) may
rely heavily on the list of questions and proceed through them without enough personalization to make the
questions relevant or understandable to the interviewee. Auditors also may become caught up in “checking off”
the questions and hardly listen to the responses. Interviewees may feel that they are being bombarded with
questions and lose the perception that this is a discussion. Auditors should view questions supplied with an audit
instrument as a guideline only and they should formulate questions in ways that are meaningful to the
interviewee.
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When choosing interview questions, the auditor must consider the interviewee and at what level the interviewee
experiences the health and safety program. For example, asking an employee who has been working for the
company for 20 years about the contents of new hire orientation may not be fruitful. Auditors often target
employees for more specific information based on their experience. Examples where this is useful include asking
questions about incident investigation to employees who have had reported incidents, asking health and safety
committee members about the OHS committee processes and activities, and asking employees hired within the
past year about their hiring and orientation experience.

Interview Planning
The interview process consists of preparing for the interviews, conducting the interviews, and summarizing
results. Preparing for the interviews includes identifying those who will be interviewed. Factors to be considered in
an interview plan are shown in the following table.

Factors Considered in the Interview Plan

 Size, structure and geography of the organization


 Hours of operation of company/ number of shifts
 Seasonal workers
 Length of interviews
 Type of interviews (individual, group, questionnaire)
 Order of interviews
 Background information about departments and employees
 Location of interviews
 Key questions for various types of employees
 Recording information from interviews
 Confidentiality of interviews
 Selection of interviewees

Table 16

Size, structure and geography of the organization


To ensure that a representative sample of employees is interviewed, the auditor must take into account the
number of people who work in the company, the locations of company facilities, the major
processes/products/services of each facility, the shifts that are worked, any seasonal worker fluctuations, if unions
are present, the utilization of contractors, and any site-specific health and safety concerns.

Length of interviews
The length of each interview will vary depending upon the number of questions required to validate audit elements
and the position of the interviewee as able to provide the required information. Generally, frontline staff is
interviewed for 20-30 minutes, and management for a somewhat longer period. The longest interviews are usually
held with professional members of the health and safety department and the health and safety committee, who
are more knowledgeable about the program details. These interviews can last an hour or more.

Type of interviews (individual, group, or written questionnaire)


The most effective type of interview is the face-to-face, one-on-one interview. With these interviews, interviewees
are generally more comfortable and are better assured of confidentiality of the information they chose to share.
These interviews also allow the auditor to rephrase questions in several ways, if necessary, and to check that the
employee understands the question. Occasionally, a one-on-one interview may require the presence of an
interpreter.
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Group interviews are sometimes useful for obtaining information from health and safety committees or health and
safety staff. The auditor is cautioned that people sometimes edit their comments when they are in a group, so
there may be individuals who are particularly quiet during group interviews who may be more expressive if
interviewed alone.

Some audit instruments permit the use of written questionnaires for a certain percentage of the worker interviews.
While this appears to be an effective mechanism to collect individual perceptions from an employee base that
may be unavailable at a specific location (drivers for trucking companies, etc.), the questionnaire process has
limitations. There is no opportunity to probe responses more fully or paraphrase questions to ensure
understanding; literacy, penmanship, and writing styles impact responses and may pose difficulties for the auditor
in reading and interpreting the responses; and employees may not trust the level of confidentiality, given that they
have provided a written document. For the auditor, the use of questionnaires does not significantly reduce the
length of time required for interviews, as the auditor must review each questionnaire in detail and make field notes
in a similar fashion as for in-person interviews. This is complicated by the limitations mentioned above. In
addition, a certain number of interviewees may choose to not send in their completed questionnaires, affecting the
sampling size.

Order of interviews
Most auditors prefer to interview senior management first and then work down the hierarchy based on the
organizational chart. This is not always possible, as the interviews are scheduled to be least disruptive to
operations. In addition, senior management availability may impact the schedule. For shift workers, it is often
most efficient for the auditor to conduct interviews during the various shifts.

Background information about departments and employees


The auditor prepares for the interviews by reviewing information about the department and individuals to be
interviewed (such as their roles and responsibilities, length of service with the company, and any special
considerations that may have led to the targeting of the employee for the interview).

Location of interviews
Interviews should be conducted in locations that provide a quiet, non-threatening atmosphere where
confidentiality can be assured. For workers, this is often in a meeting room near the work area; for management
staff, interviews are often conducted in their own offices.

Key questions for various types of employees


Questions to validate various audit elements are designed for senior management, management, supervisory
staff, workers, and contractors. All questions cannot be answered by all those interviewed, as their roles and
responsibilities bring expectations of awareness of different aspects of the element. In audit instruments that
provide prepared questions, the questions are usually broken down into groups to be used with the various levels
of management and staff. For those auditors designing their own questions, it is important to look at the interview
validation requirements, which may specify, for example, that a majority of supervisors must respond positively to
validate a specific question.

Recording information from interviews


Novice auditors often make the mistake of thinking that they will remember what an interviewee has said during
the course of the interview. This, coupled with a level of inexperience in writing notes while conducting the
interview, often leads to insufficient information being recorded. The auditor must take sufficient notes to be able
to reconstruct the response and to ensure that examples provided by the employee are available to justify the
final evaluation or score. Interviewees should be made aware of the auditor’s need to take brief notes. The note-
taking should not dominate the interview process, but should complement it. Experienced auditors have learned
to use symbols and brief “trigger” words that will enable a more descriptive summary to be written later.

In general, interviewees do not feel comfortable having their interviews taped, nor do they feel a personal
connection when the auditor is typing responses into a computer as the interview progresses. Some electronic
instruments encourage the taking of interview notes directly into a computer. In this case, the auditor may choose
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to use this method, but may also choose to facilitate a more personal connection by taking written notes and
completing the electronic interview note section in between interviews.

Confidentiality of interviews
The auditor assures the interviewee that all responses will be kept confidential. This implies that interviewee
names are not disclosed, nor is any information provided on the audit report that would suggest the interviewee
as an obvious source (e.g., when there is a small department, or a unique position referred to).

Selection of interviewees
The selection of interviewees was addressed earlier in this guide. Auditors must understand the organizational
structure, the roles and responsibilities, work schedules, and the numbers of all levels of employees to ensure a
representative selection is made for interviews. In addition to having a representative sample for interviews, the
auditor may be required to have a flexible approach to selection of interviewees. In some case, the nature of the
work may lead to the interviewees being selected on the day of the interview rather than booked in advance. In
this case, the auditor must ensure that the appropriate types and levels of employees are selected. The company
contact usually provides assistance in the selection and scheduling of interviewees, bearing in mind the required
levels, the employee schedules and workloads, and the need for any targeted interviews.

Conducting interviews
In conducting the interview, the auditor must balance the need to obtain specific information with the need to
ensure that the interviewee is comfortable and is speaking openly. For some auditors, this is a challenge, as the
auditor may become side-tracked by trying to make the interviewee comfortable. The quality of the interview
impacts its outcome, which should be the recording of relevant information while instilling confidence in the
interviewee that the information they are providing is useful and will be kept confidential. The more experience an
auditor has with interviewing, the more easily the interviews proceed. Interviews generally have three phases –
the Opening, the Questioning, and the Closing.

Interview Phases
OPENING QUESTIONING CLOSING

Clarification
Introduction Questions
Reflection
Explanation Listening
Transition

Figure 4

Opening Phase
The beginning of the interview often foretells its success. The interviewee must feel comfortable in the interview
location, have time to collect his or her thoughts and make the transition from work activity to focus on the audit.
The auditor also needs to make the transition from the last interview (or other activity they were conducting) and
focus on the interviewee’s needs, initial attitude and concerns.

The auditor sets the tone for the conversation in the introductory comments. He or she tries to put the interviewee
at ease by making eye contact, asking him or her to take a seat, asking questions about where the employee
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works and what his or her job is, and generally establishing a good rapport. The auditor proceeds with providing
an explanation of the interview process, assuring confidentiality, and explaining that the auditor will be taking
notes during the interview. If the auditor notices that the interviewee is anxious, this explanation may take longer,
and the interviewee should be assured that the interview is not a test and there are no “correct” or “incorrect”
answers.

The auditor then transitions the interview to focus on the specific questions that will be asked. An initial question
often used in this transition is an open-ended “Would you please describe your work activities and how you are
involved in health and safety?” This sets the stage for the more detailed questions that follow.

Questioning Phase
The auditor must be vigilant about the duration of the various phases of the interview. Effort is often required to
ensure that all required questions are asked in the designated time frame of the audit. An experienced auditor
usually prefers to ask some broad general questions, and then, taking into account the interviewee’s
understanding of the health and safety system, delve into more detail to answer specific audit questions. For
example, the auditor may ask the interviewee to describe how health and safety is managed in the company.
From that question, the auditor can probe specific roles and responsibilities, how these are monitored and
evaluated, and how workers are made aware of their responsibilities.

It is not usually possible or advisable to ask each employee all the questions required by the audit instrument. The
pace would be too quick and both the employee and the auditor would likely feel too rushed. The auditor should
determine what questions will be asked of each employee, making sure that there are sufficient responses to
each question to enable the auditor to be confident that he or she is obtaining a representative sample. There are
some questions that will be best addressed by specific groups of employees. For example, when asking
questions related to the orientation program for newly hired workers, the auditor will want to ensure that these
questions are posed to employees hired within the past year. Questions related to work conducted by health and
safety committees should be addressed to committee members. One question that is quite useful to ask any or all
employees is a good one on which to end, “What improvements would you recommend for the company’s health
and safety program?” This may provide information that is not uncovered in the specific interview questions,
provides good suggestions that may be integrated into recommendations, and reaffirms that the employee’s
interests and suggestions are sought and valued.

A critical aspect of interviewing is the posing of open-ended questions. These are questions that are not
answered with a simple yes or no, but require the interviewee to provide more detailed information. The auditor is
often challenged by the requirement to give sufficient time to the interviewee to collect thoughts and respond
completely to the question. Novice auditors sometimes become impatient and push the interviewee to respond
quickly (and often incompletely). There is a need to balance quantity and quality of information; auditors are well
cautioned to ensure that they actually listen to the responses and avoid asking “leading questions” that telegraph
the expected answer to the interviewee. This is more likely to occur later in the interview schedule, as the auditor
gains confidence that he or she is obtaining an accurate picture of the status of the health and safety system. The
auditor must stay focused on the interview and not assume or predict the interviewee’s responses. The novice
auditor is less likely to actively listen to the response of a question, but instead listens for key words that will allow
the auditor to mark the question as having a positive or negative response, and focus his or her attention on
asking the next question. Active listening encourages the interviewee to provide more complete information.

Tips for Active Listening


 Maintain eye contact
 Summarize what the interviewee has said
 Be aware of emotional words and tone of voice
 Avoid disruptions or interruptions
 Take notes
 Paraphrase to confirm understanding

Table 17
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Taking notes is both a way to ensure active listening, and a critical technique for recording information. Given the
need to identify specific issues for follow-up, auditors frequently develop a short hand notation system that
includes symbols to identify what must be checked or followed up upon, or what may be useful for
recommendations.

Interviewing people gives rise to a variety of potential issues that are common in all types of human
communication. This includes experiencing a wide range of personality types, motives, perceptions, and
communication styles. In addition to interviewee communication factors, auditors also have personalities and
styles that impact communication. The experienced auditor knows how to read “body language”, how to avoid
telegraphing their own impressions and feelings, and how to identify and deal with resistance, anger, fear, and
other emotions.

As the auditor chooses those to be interviewed, it sometimes happens that the interviewee is an unwilling
participant. This can occur when the individual is fearful that what they say will not be held in confidence, when
there is a history of animosity towards the employer, when the labour relations climate is stressed, or when the
employee resents being chosen for an interview. Resistance can be displayed in a number of ways. The
interviewee can simply refuse to answer specific questions, purposely give an answer which does not address the
question asked, ask the auditor to repeat the question several times, or display anger towards the employer and
sidetrack the interview into personal issues. In all shows of resistance, the auditor must respect the interviewee,
restate the commitment to confidentiality, and steer the conversation back to the desired interview questions.

Auditors are responsible for keeping the interview on track. This is not always easy, both because time is limited,
and because communication styles vary considerably. Critical questions must be asked in all interviews; this
means that the auditor must find ways to gently lead the conversation back to the critical issues. It is not always
the interviewee who diverts the interview - chatty auditors are also guilty of causing the interview to go off track.

Closing Phase
The auditor should move into the closing phase of the interview in the last 4-5 minutes. Recapitulating what has
been said in the interview is a good way to ensure that the information gathered is correct and the auditor has
summarized the critical points correctly. The auditor looks quickly back through his or her notes, summarizing the
main points, especially those that he or she indicated by symbols as items to check back on, follow-up with, or
make recommendations about. This form of paraphrasing also ensures the interviewee that the auditor has
captured what he or she was saying.

Once the summary is completed, the auditor asks the interviewee if he or she has any questions, and lets the
interviewee know how the information collected will be used, describes the next steps for the audit, and provides
the interviewee with contact information should there be any questions. Interviewees sometimes ask questions
related to the availability of the results. It is best to clarify that with the company contact person prior to the start of
the interview process. Some organizations make the entire audit available to employees, some provide a
summary, and others provide access only to management staff.

The auditor ends the interview on a positive note, and thanks the employee for his or her participation and
valuable input into the audit process.

The auditor should allow at least five to ten minutes between interviews to make any summary notes necessary
and allow for a transition to the next interview. Interviews that are properly conducted, with the auditor fully
“present” and engaged in active listening, are tiring; more than about ten interviews in a day can leave the auditor
quite exhausted. The experienced auditor paces himself/herself well and sometimes interjects site visits or rest
periods between groups of interviews.
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Site Tours – Familiarization Tour


The auditor normally has two site tours during the course of the audit. The first most often occurs early in the
audit, usually on the first day, following the kick-off meeting. The purpose of this tour, called the “familiarization
tour” is to enable the auditor to have an overview of the facility, what processes are conducted, where and how
employees are working, and the general layout of the plant. The auditor forms first impressions about how the
health and safety system functions, as it is demonstrated by the housekeeping, orderliness, and lack of clutter
and congestion. Whether employees heed rules for wearing personal protective equipment and following safe
work practices is sometimes readily apparent in the familiarization tour. This tour also sheds light on the style and
content of management communication about safety in the workplace. This is not a very extensive, detailed tour,
but rather an overview, through which the auditor should become familiar with aspects listed in the following table.

The Familiarization Tour – Desired Outcomes

 Logic and history of facility layout


 Outdoor versus indoor activities of the workplace
 Location of areas of major activities including administrative functions, operations, laboratories, shipping
and receiving, etc.
 Locations of fixed and mobile equipment
 Storage areas
 Location of sources of environmental emissions
 Locations of electrical and mechanical facilities and controls
 Location of exits and evacuation paths
 Locations where health and safety documents are kept or available.

Table 18
The auditor should wear the appropriate personal protective equipment in all work areas visited during the
familiarization tour.

The auditor uses the five senses (Figure 5) to obtain a clear picture of the environment in a short period of time.
Some of the observations that reflect on the health and safety management system include the following.
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Eyes:
 Cleanliness
 Signage
 Spills
 PPE use
Nose:
Ears:  Smells
 Noise
 Employee
remarks Auditor’s Senses
 Warnings Active during
Observation Tours

Mouth: Touch:
 Tastes  Vibration

Figure 5

The auditor obtains an overview of the organization during the familiarization tour. Environmental conditions such
as noise, lighting, temperature, egress, congestion of the work area, orderliness, and facility condition (including
damages, etc.) are readily evident to the auditor during this walk- through. In addition, the auditor notices several
aspects while observing workers, including their use of required controls, how they are using tools and equipment,
the speed at which they work, the number of people in the area, and how attentive they are to their work.
Equipment is also noted during this tour. The auditor notices if equipment has guarding, signage, lock out or tag
out practices, and is well maintained.

This familiarization tour is not designed to be a comprehensive review of the facilities and processes. It therefore
has several limitations and the auditor must be cautious about drawing too many far-reaching conclusions during
the familiarization tour.

Limitations of the Familiarization Tour

 Observations may not cover all functions that are normally occurring
 Observations may not be in the scope of the audit
 Implications for audit findings may need to be validated by other methods
 Opportunities to ask questions may be limited
 The tour guide may not be able to provide answers to health and safety-related questions
 It is sometimes difficult to take notes during the tour.

Table 19
The familiarization tour must be carefully planned and include major areas and processes, so that the auditor has
a good understanding of how the company functions. A representative of the company usually acts as a tour
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guide, explaining the processes and answering questions along the way. In very noisy environments, it is
beneficial to stop periodically to ensure that there is an opportunity for questions and answers. In the case of a
team audit, it is usually advisable to have all team members participate in the familiarization tour, as the tour helps
the auditors gain the necessary understanding of the environment and processes.

Site Tours – Observation Visits


Several audit questions specifically require observation as a validation method. These questions usually are those
where direct observation of the policies and procedures in practice assists in determining the level of compliance.
This requirement for observation ensures that the policies and procedures are not just theoretical documents, but
are substantiated by observation as implemented.

The observation tour may take longer and is usually more targeted than the familiarization tour. It occurs after the
auditor has conducted the document review and often after or in conjunction with the interview phase, as items
reviewed in the documents or disclosed in the interviews may need verification by an observation visit to a
specific area. The auditor chooses sites to visit based on notes he or she has made during documentation and
interviews.

Examples of Items Verified in Observation Visits

 Location and availability of policies


 Availability of applicable legislation
 Completed corrective action related to specific incident investigation or inspection reports
 If workers are wearing required PPE
 If required engineering controls are in use
 First aid supplies
 Emergency response procedures and equipment

Table 20
In either type of tour, the auditor may come upon a situation (work environment or work procedures) that he or
she believes is dangerous to the workers or the public. The auditor must be able to ensure that work that may be
imminently dangerous is stopped immediately. This is a legal requirement, and should be addressed by the
auditor in the initial contract. The most effective way to stop work is to have the immediate supervisor actually
direct the work to stop and then follow the required procedures to address the dangerous situation.

The observation tour enables the auditor to informally ask workers questions. Any questions should be brief and
should not be disruptive to the work process.

Notes taken during the observation visits must be incorporated into the rest of the audit notes and added to the
audit field notes. Notes should include the location and time of day the observation occurred.

In cases where there are multiple sites, the company may request separate observation reports for each site. This
provides the company with more specific information applicable to each site and enables the site to develop
action plans related to specific observations. These additional site observation reports are not usually part of an
audit and are provided at the discretion of the auditor, usually at a company’s request.

The auditor may request the right to take photographs during the observation tour. Photographs are useful in
illustrating specific hazards or positive observations, and may be included in site observation reports. If the
company permits the taking of photographs, the auditor should avoid taking photographs that include people, but
rather focus on equipment and conditions.

Audit Close-out or Debriefing Meeting


At the end of on-site activities, it is customary to have a “debriefing” meeting, which is usually a face-to-face
meeting between the auditor(s) and company representatives (often the same individuals who attended the kick
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HSE Auditing

off meeting). The meeting also may be conducted by teleconference if several sites are involved in the audit. This
meeting signals the end of on-site activities and the beginning of the final, report-writing phase of the audit. It
should be remembered that final scoring (of scored instruments) or final evaluations are not yet completed, so the
type of information presented at the debriefing meeting is necessarily incomplete. The debriefing meeting has
several purposes.

Purpose of Audit Debriefing meeting


 Signal the end of on-site information gathering
 Restate purpose and scope of the audit and the methodology for verification methods used
 Provide general recommendations that are obvious to the auditor from the initial review of information
collected
 Identify clear strengths that are evident to the auditor
 Thank those involved in the coordination of the audit, as well as all participants
 Answer any questions from company representatives.

Table 21
The debriefing meeting often lasts between 45 minutes to an hour, though the time may vary with the number of
participants. A typical debriefing meeting agenda is illustrated in the following table.

Audit Debriefing Meeting Agenda

 Introductions
 Restatement of audit purpose, scope and validation methodology
 Review of positive observations
 Review any preliminary recommendations for each audit element
 Review of next steps in the audit process, including timelines
 Questions and answers

Table 22
In some cases where multiple sites are visited, the auditor may be requested to provide individual site
“debriefings.” This is usually well appreciated by the management at specific sites, as it enables them to obtain an
overview of the positive and negative findings for their specific site. These individual site debriefings are usually
informal and short.

Completing the Audit


Once the on-site activities are completed, the audit findings must be aggregated and evaluated and the final audit
report must be written. The type and contents of the report may vary considerably with the instrument used, as
well as any requirements of certifying bodies. Some instruments have very specific report requirements, even
specifying the terminology that may or may not be used. The auditor should verify report requirements before
starting to write the report. Electronic instruments may collate the various sections and produce a report with a
consistent format.

Scoring an audit (scored instruments)


In an effort to ensure uniformity and consistency of scoring, many scored audit instruments have very stringent
validation requirements. Scoring generally is of two types – the “all or nothing” scoring (e.g. 0 or 5 points given) or
“range” scoring (e.g., 0, 1, 2, 3, 4 or 5 points allowed). These traditionally are designated as “(5 points)” for all-or-
nothing questions worth either 0 or 5 points, or “(0-5)” for a range questions worth any number of points between
0 and 5 to 5 points.

Range scores often require more professional judgment and may lead to inconsistent scoring; however, this type
of scoring allows the auditor to award partial points to give credit for what the employer may have in place, even if
it doesn’t quite meet the standard.
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In any scored instrument, the auditor is required to justify the scores awarded for each section or question. In
some situations, “N/A” may be used if the question is not applicable for the particular employer. N/A is used
infrequently, and only when the question does not apply to a specific employer. For example, if a small company
does not have supervisors, then questions requiring a response specifically from supervisors would be scored
N/A.

It may be necessary to pro-rate scores for documentation that has not been in place for a full year. In cases
where the company develops a policy or procedure only weeks before the audit, very few points are awarded.
However, in the recommendation, auditors sometimes indicate that the newly developed policies or procedures
are a good starting point and will be fully counted in subsequent audits.

For scored instruments, instructions for scoring are usually very detailed and must be rigidly adhered to.
Instructions usually cover several different scoring issues. These are summarized in the table below.

Scored Audit Instructions


 The percentage of positive indicators required to allot points in “all or nothing” questions
 When the use of N/A is allowed
 What types of validation methods are required for each question
 Whether scores should be rounded off and in what way
 The number of sites to be visited and the number of people to interview
 The format of field notes and final report

Table 23
Scoring by an Audit Team
In team audits, the lead auditor usually makes the final scoring decisions after discussions with the audit team
members. Generally, the lead auditor takes into account the experience of the team members. Frequently novice
auditors score significantly higher or significantly lower than experienced auditors for the first couple of audits they
conduct; this is primarily a result of their more limited perspective of how the various system elements can be
implemented. With electronic instruments, individual scores and notes may be automatically amalgamated and do
not take into account the experience of the auditor.

Scoring Errors
Quality control reviewers of scored audit instruments often discover similar “common mistakes” made by auditors.
The following chart lists some of the more frequently occurring errors related to scoring audits.
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Common Scoring Errors


 Math errors
 Inconsistent “rounding off”
 Inconsistency between scores and justification
 Awarding points as “range scores” when “all or nothing scoring is required”
 Using N/A inappropriately
 Using improper validation methods
 Not deducting N/A points from the total possible points for the audit

Table 24
Some electronic audit instruments have built-in control features to correct these mistakes.

Results Using Un-scored Instruments


Un-scored instruments are often preferred by professional auditors, as there is frequently more leeway in how the
final report is written. The auditor may be better able to make recommendations that address systemic issues
noted in the course of the audit that will significantly assist the company in improving its program. These
recommendations may be considered out of scope for some scored instruments and therefore not permitted in the
report.

Unscored audits enable the auditor to identify system “ themes” for improvement. For example, the auditor may
note that there is little participation by employees in several processes, such as inspections, incident
investigations or hazard assessments. Another example of a system theme is lack of documentation (for training,
drills, hazard follow-up, etc.).

For compliance audits, or for those designed to provide a conformance/non-conformance assessment of the
company’s system, the auditor must be certain that he or she has correctly understood the directions and applied
the criteria to determine compliance or non-compliance. Reference to the specific standard is usually required.

For some audit instruments, results are primarily in the form of “yes”, “no” or “partial” meeting of a standard. In
some cases, there is a section as to what actions must be undertaken to completely meet the standard.

Depending upon the structure and contents of un-scored audit instruments, they can vary considerably in their
usefulness to a company in helping to formulate an action plan to address deficiencies and make program
improvements.

Field Notes
Field notes are used to justify scores in scored instruments and to provide examples to support evaluations in un-
scored instruments. Some audit instruments specify the type, format, and content of field notes, while others
leave these to the discretion of the auditor. In all cases, field notes should provide the company with an
understanding of the evaluation results. Field notes usually refer to the validation method used (e.g. “75% of
workers interviewed indicated that they had received health and safety orientation in their first week of work”;
“20% of incident investigation reports reviewed identified root causes of the incidents”).

For audit teams, the information gathered for each question by each required validation method must be
integrated to determine a score, or other evaluation result. If four team members interviewed a total of 80 people,
the interview validation would require adding all of the positive responses together and dividing by 80, then
multiplying by 100 to obtain the score.
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Example of team scoring results


# who were asked the # positive responses # negative, no comment
question responses
Team Member 1 15 10 5

Team Member 2 20 18 2

Team Member 3 20 14 6

Team Member 4 25 21 4

Total 80 63 17

63/80 = 0.7875 X100 = 78.75% = 79% (rounded off to nearest whole number)

Table 25
Non-conformances and Corrective Action Requests (CAR)
Un-scored audit protocols (such as those evaluating systems relative to ISO requirements) may require a report
of non-conformances to standards and the development of corrective action requests (CARs). The CAR is a
factual statement of the non-conformance identified, which element it relates to, and includes a reference to
company documents, interview responses or observation related to the issue (basically the same information as
provided in the field note).

In some audit instruments, findings are restricted to identifying deficiencies, citing the standards where non-
conformance has been identified, and citing the validation information. In these, there may be a strict requirement
to offer no recommendations, relying on the company to develop its own remedial action plan.

Recommendations
In audit instruments requiring or permitting recommendations, the auditor has an opportunity to provide significant
value to the organization. Writing recommendations, however, can be challenging. For each element, the auditor
usually identifies the company’s successes and strengths related to the element, as well as areas where
improvement is warranted. Several guidelines that are useful in writing recommendations are listed in the table
below.
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Guidelines for Writing Recommendations

 Ensure that the number of recommendations reflect the score or number of non-conformances. Elements
in which a low score or many non-conformances are noted should warrant more (and stronger)
recommendations.
 Keep the number of recommendations reasonable. The number of recommendations should not be
overwhelming.
 Make recommendations that are reasonable and achievable.
 Ensure that a feature identified as a “strength” of the company’s system is, in fact, a strength, and not just
a first step in meeting a standard.
 Avoid putting recommendations in the strengths section.
 Avoid contradictions, such as making a recommendation to correct an identified strength.
 Stay within the scope of the audit. The auditor should not be addressing aspects of the company that are
not covered by the audit instrument.
 Avoid being prescriptive in writing recommendations. Focus on the outcomes desired, rather than telling
the company how they should attain the desired results.
 Ensure that recommendations address management systems, rather than inspection items or other
symptomatic deficiencies.
 Include a perspective of how the recommendations, if followed, will benefit the company.
 Prioritize the recommendations within each element.
 Consider the company culture and communication style when composing the recommendations.
 Ensure that any compliance issues are referenced.

Table 26
Liability Concerns with Regards to Recommendations
Auditors are required to be careful in the wording of recommendations to avoid having the document raise liability
issues for the company. From a due diligence as well as a freedom of information perspective, statements by a
health and safety professional indicating that a company “must” or “shall” take some specific action may be
perceived as constituting a legal requirement. Audit recommendations are just that - recommendations (hopefully
well written to avoid prescriptive directions) that a company may utilize in developing its action plan to improve the
health and safety management system. The auditor should be careful in the wording of recommendations, and
reserve the use of “must” for clear cases of non-compliance with referenced legal requirements.

The Audit Report


Audit instruments may be detailed to the extent that the contents of the audit report are well-defined. In other
cases, the format of the report is left to the auditor’s discretion. A typical audit report contents are listed in the
following table.

Audit Report Contents


 Title Page
 Executive Summary
 Description of Methodology
 Company Profile
 Element Profiles – strengths and recommendations in each element
 Scoring summary (if scored)
 Conclusion
 Completed audit instrument (checklist or scored instrument)
 Field Notes

Table 27
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In some cases, for accreditation, quality control, or certification purposes, the auditor is also required to include
pre-audit communications, a company organizational chart, “kick-off” meeting notes, the sampling strategy, the list
of documents reviewed, observation tour notes, and closing meeting notes. Auditors may use checklists to ensure
proper submission of all documentation required to complete the audit report.

The importance of writing style cannot be overemphasized. The quality of the writing, as well as the use of proper
spelling and grammar, often impacts the credibility of the report. Auditors who do not have strong writing skills are
advised to seek additional education and guidance to improve these important skills.

The auditor should deliver the report on time and in the format agreed upon. This may include a certain number of
hard copies of the audit, as well as an electronic copy (usually as a PDF file). In some cases, the completed audit
must be sent to a certification body for a quality control review prior to submitting it to the audited company.

The Audit Report Presentation


In many cases, the auditor is requested to formally present the audit findings/results to company representatives.
Typical presentation points are listed in the table below.

Agenda for Audit Report Presentation


 Greetings
 Introductions
 Identified strengths and recommendations for each audit element
 Review of scoring (if applicable)
 Closing comments
 Question period

Table 28
Some company representatives at the audit report presentation may question the scoring or non-conformances
identified, or provide examples that support their views that these results are not accurate. The auditor can
usually dispel these concerns by ensuring that the company representatives understand that the audit captures a
“snapshot” of the system at a specific time, and that results are based on the use of specific validation methods to
provide an overall picture of the company’s system.

Other audit report presentation responses may include a request for changes to the document (which the auditor
may or may not do, depending on the nature of changes as well as any contractual agreements made related to
changes), requests for more information (especially for referenced legislation, etc.), requests for costing of
recommendations (usually outside the scope of the audit itself), and requests for assistance in developing action
plans to address audit recommendations.

Supplemental Reports
As mentioned previously, the auditor may be requested to provide supplemental reports, such as site observation
reports. Another common request is for a more detailed “inspection” of a specific area with a separate report.
These are out of the scope of an OHS management system audit and not considered part of the audit report. The
auditor who agrees to the supplemental report(s) should ensure that the company understands that these are not
part of the audit and that copies of these reports are not submitted to certification bodies, but remain the property
of the company only.

Action Plans
Some certifying bodies provide an “action plan” option for the years in between required external audits. In this
case, a specific action plan format is followed. This usually includes the description of 5-10 objectives based on
the previous year’s audit recommendations. The objectives must usually be accompanied by specific milestones,
designation of responsibilities for meeting the objective, target dates and deliverables. There are various
submission requirements related to action plans.
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As mentioned, auditors may be requested to assist in the development of action plans. While this may be
tempting from a consulting perspective, the auditor should approach this request with caution. It may impact his or
her ability to perform future audits for the company. In addition, and more importantly, audit action plans are
usually most effective if they are designed (and therefore “owned”) by internal members of the company. The
auditor can assist by identifying top priorities for an internal action plan group.

Future Audits
Some certification bodies limit the number of times an auditor may perform the audit for the same company. While
continuity has benefits for a few years, the fresh perspective provided by a different auditor is recommended after
three or four audits.

Auditing the Auditors


Certifying bodies have quality control processes in place to ensure the quality of audits performed by auditors.
The quality control processes often relate to the following aspects of the audit process and report:

 Timing requirements for the performance of the audit


 Timing requirements for the submission of the audit report
 Sampling strategy for interviews, documents and representative sites
 Application of appropriate scoring methods (for scored instruments)
 Justification of scores
 Contradictions between similar questions
 Calculation of scores
 Appropriateness of recommendations
 Appropriateness of identified “strengths”

In addition, the company audited may be requested to complete an auditor evaluation that would cover
performance aspects.

In addition to these quality control processes conducted by certifying bodies, there may be additional oversight
audits conducted. For example, the Province of Alberta has instituted a review process for On-Site Audit Reviews
(OSARs). According to their website,

“OSAR is a limited, on-site review of the work completed by an external auditor. OSARs will be conducted
within 120 days of an external audit, and are designed to provide the Certifying Partner (CP) with valuable
information about auditor performance. These reviews also help to confirm that employers are receiving
thorough and complete audits that will help them identify areas where their health and safety
management system may need improvement.

The review involves a short interview with the audited employer, and a review of key documentation that
would have been reviewed by the original auditor. Once the original audit report is approved and finalized
by the CP, the OSA Reviewer completes the process by comparing their findings with those in the final
report.”
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GLOSSARY of TERMS
Audit (OHS) A gap analysis of the status of health and safety management system elements compared
to a set of standards.

Audit instrument A tool that describes the standard and identifies information to be obtained about the
company’s status relative to the standard. It identifies required validation techniques for
each standard and provides directions for the completion of the all questions.

Audit scope The aspects of the company being audited, including sites, operations, etc.

Corrective Action A factual statement of the non-conformance identified the element it relates to, and
Request (CAR) includes a reference to company documents, interview responses or observation related
to the issue.

Debriefing meeting A meeting (usually face to face) that signals the end of on-site activities and enables the
auditor to provide general observations.

Directive A company’s documents that describe what should be done and how it should be done.
documents Examples include policies, procedures and blank forms.

External auditor An auditor from outside the company that audits the company.

Familiarization tour The initial tour of the worksite conducted to provide the auditor with an overview of the site
and processes.

Field notes Explanatory notes the auditor provides for each audit question that justifies the score or
findings. These usually include the validation methods used.

Inspection A systematic review of processes, procedures, equipment and materials to ensure that all
potential hazards are being controlled.

Internal auditor An auditor who is an employee of the company and conducts the audit for the company.

Kick-off meeting The meeting the initiates the audit activities and is often conducted on the first day of the
audit. It provides the auditor with an opportunity to review the audit process and respond
to questions.

Life Cycle of Refers to how documents originate, where they go and what is done with them from their
documents creation until they are filed or considered complete.
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Observation tour A planned tour to validate those audit items that need to be directly observed by the
auditor, such as the posting of lists of emergency response personnel, condition,
availability and use of personal protective equipment, use of engineering controls, etc.

OHS management A framework of accountabilities to ensure that OHS critical components are developed,
system implemented, and documented.

Operational Documents that show what actually occurs in the company, in contrast to directive
records documents. Examples of operational records include training attendance lists, completed
workplace inspection forms, completed incident investigation forms, etc.

Validation method A (usually specified) technique to verify the performance to the standard. The three major
validation methods for OHS management system audits are document review, interviews
and direct observations.

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