Taking a proactive approach to safety and ensuring compliance within your company is critical.
By Alexandra Walsh
A regulatory workplace safety audit is the most comprehensive way there is for a company to gauge the efficiency, effectiveness, and legality of its safety management system.
Besides being sure a business remains compliant with local, state, and federal legislation, safety audits can identify and correct oversights that, if left unchecked, could lead to costly and tragic workplace injuries or fatalities. When audits successfully uncover weaknesses in an employer’s safety programs or practices, these also prove to be important tools in designing a new safety plan.
Safety Audits and OSHA
When people think about safety audits, the Occupational Safety and Health Administration tends to come to mind because the agency expects businesses to audit their operations with regularity. Likewise, audits are the most reliable way to avoid OSHA’s penalties by uncovering problems related to compliance before they lead to violations.
A proactive approach to safety and ensured compliance within your company is critical. Equally critical, at the same time, is that employers understand the benefits—and potential liabilities—initiating these measures can create. It is pointless to undertake a voluntary safety audit if you are not prepared and willing to produce the required changes based on the results.
OSHA distinguishes between “willful” and what could otherwise be described as “passive” violations, knowingly allowing a safety hazard to exist that carries serious consequences, including potential criminal penalties. As a result, if you conduct a voluntary self-audit, discover a serious hazard, and then do nothing about it, you will be exposing yourself (and your employees) to a host of negative consequences.
When done properly, these audits can serve the dual purpose of improving safety for employees and bolstering certain legal defenses, because they demonstrate that a proactive investigation of safety violations has taken place.
For example, two of the four elements of the “unpreventable employee misconduct” defense to an OSHA violation are: first, the employer insisted on compliance with safety rules and had methods of discovering violations of its rules; and secondly, the employer had effective enforcement mechanisms in place. Conducting safety audits on your own accord—and retaining written documentation of such audits—can be instrumental in establishing these two elements.
Verifying OSHA compliance is only one function of a safety audit, but it’s a great place to start. OSHA’s regulations form the foundation of an effective safety program but are the bare minimum of what every employer should be doing in the first place to keep workers safe.
Who Should Audit
Assembling a safety audit team within the company can be beneficial as employees obviously should be the most familiar with both the safety rules and the physical layout itself. If the audit is conducted internally, it may be a good idea not to allow team members to conduct audits of their own departments, for the sake of objectivity.
What to Include
The audit should determine if the company’s safety measures meet these four essential objectives:
- Do existing measures cover all regulatory and best industry practice requirements?
- Are the program requirements being met?
- Is there documented proof of compliance?
- Is employee training effective—can and do employees apply specific safe behaviors?
What to Ask
Examples of questions safety team member auditors should ask include:
- Are all employees trained properly?
- What are the safety policies, and are employees following them?
- Is there any written compliance program in place?
- Has the company conducted a hazard assessment?
- What is the condition of personal protective equipment?
- What are the chemical storage procedures?
- Does the company have all required hazardous materials paperwork?
- What are the machine guarding (lockout/tagout) procedures?
- What are the respiratory protection procedures?
- Are there any fall hazards present in the workplace?
- What are the shipping, warehousing, and transportation procedures?
- Are sprinkler systems in good working order?
- Are all necessary safety signs in place?
Employers should consider developing a priority based on the hazard level to see that the most egregious violations are corrected first. A written schedule for corrective action should be created and enforced. Further, the findings should be communicated to all managers and supervisors to promote transparency and awareness in your workplace.
In addition to looking out for workforce health and safety concerns, an audit should check to see whether the facility is adhering to U.S. Environmental Protection Agency regulations:
- Does the facility generate hazardous waste?
- Is there an Environmental Protection Agency ID number?
- Is the generator status and owner information accurate?
- Are all the hazardous waste manifests organized and kept on-site?
- Does the facility require an air permit? Is it on file? Does it need to be updated?
- How many storage tanks are kept on-site? Do they need to be registered?
- Does the facility have a Spill Prevention Control and Countermeasure Plan in place?
- How about a Stormwater Pollution Prevention Plan?
- Are there any hazardous chemicals stored on-site? What chemicals and how many?
Some regulatory audits address the entire facility while others are more specific to departments. When it comes to companies whose employees are required to drive company vehicles, an audit should pay close attention to any Department of Transportation compliance issues:
- Are hazardous materials loaded and unloaded properly?
- Are hazardous materials shipped on-site?
- Are employees trained on DOT regulations?
- Are the proper DOT signs posted?
National Fire Protection Association standards may seem less significant than either OSHA or EPA compliance, but it is certainly in a company’s best interest to prevent anything that has to do with fires:
- Does the facility’s on-site chemical storage require a hazardous materials permit, either from the state or local fire department?
- Has the sprinkler system been inspected?
- Are any sprinkler heads obstructed?
Be aware too that some fire departments require a hazardous materials inventory, so they know what to expect if they need to respond to an emergency at the business.
Regulatory compliance is only one function of a safety audit. Audits also serve to proactively reduce workforce safety risks and improve efficiency. In other words, an effective audit goes beyond just keeping the company in line with the letter of the law.
If you’re only conducting audits to ensure compliance, you’re missing the point: You’re missing critical opportunities to keep people safe and save money.