Let’s face it; we’ve all been there, facing the impending doom that follows a compliance audit by the “guys from corporate.” As the audit concludes there is a laundry list of findings that must be addressed. The facility manager verbalizes his or her commitment to making team-based improvements and getting the issues resolved in a timely manner. Hands are shaken, niceties are exchanged, and the audit team departs. Then, a meeting is held and the responsibility for getting the identified issues resolved is placed squarely on the shoulders of the “safety guy.”

Sound familiar? As the leaders of these important exercises, that is to say, those involved in planning, conducting, or participating in audits, we’ve allowed compliance audits to become stale and routine. And more importantly, compliance audits too often have little to no correlation to actual injury and illness performance at the facility. However, as leaders, we have the ability to be more creative with our audit processes in an effort to get more value out of them.

Compliance Audits – Are They Necessary?

The purpose of this article is not to dispute the need for compliance audits. Quite the contrary! In a world that expects transparency, compliance audits are required for strong corporate governance and are a critical component in the Plan-Do-Check-Act cycle. Company legal departments and boards of directors alike are compelled to know whether their operations are complying with regulatory requirements and also, what steps must be taken to achieve and maintain compliance. The question is, with the focus predominantly on compliance are we letting our most precious resource, our employees, down? Many times, a traditional compliance audit misses the forest for the trees. That is, our audit team identifies many compliance issues, but fails to identify the issues that are causing injuries to employees.

Shortcomings of Traditional Compliance Audits

As a compliance auditor and former auditee, I’d like to offer a few observations regarding limitations of traditional compliance audits.

Traditional audits are routine and repetitive. Many organizations have been auditing their environmental, health and safety (EHS) programs for years with no significant changes to the process. The effect of this is an audit program that has become routine and repetitive. The audits are predictable and therefore generate little enthusiasm or urgency for performance improvement. Rather, audits have become a “ride the storm out” type of exercise.

Traditional audits may not focus on critical risks. Traditional audits tend to focus on broad compliance topics (e.g., hazard communication, safety data sheets, emergency egress, confined space entry) and the regulatory obligations within these broad subjects rather than focusing on the behaviors that put employees at risk every day. By focusing on compliance with regulations and programs and procedures rather than behavior, auditors may inadvertently gloss over the greatest risks facing our employees. Have we forgotten the fundamental point of all of these regulatory obligations, which is to prevent injuries?

Traditional audits engage a limited number of staff. Although the entire facility management team is typically present at opening and closing conferences, it often becomes clear as the audit progresses that the EHS manager, not the facility, is being audited. The EHS manager may bring in technical specialists or subject matter experts to assist in fielding certain questions or provide specialized insight into a process or control device, but traditional audits seldom involve the wide participation of the employees who are most likely affected by poor safety performance. Indeed, often times during the closing meeting, it is easy to see that the responsibility for implementing corrective and preventive actions falls squarely on the shoulders of the plant EHS manager and leaves other staff members uninvolved to the point where they can easily disengage from the process.

It appears that as those responsible for scheduling, conducting, and participating in compliance audits, we’ve chosen the path of least resistance, and allowed our audits to become routine, repetitive, and predictable. The result of this choice is a process that may identify compliance issues, but doesn’t prevent employees from getting hurt.

A Better Way to Audit

To get more value out of EHS audit programs, we must consider placing a greater focus on people, behavior and culture while continuing to maintain our focus on compliance. Here are three key changes that could make a big difference.

Challenge current conditions (the “status quo”). If we really want to improve EHS performance, audits must become a tool for changing behavior. To do this, we need to cause a fundamental shift in the way that people think about and manage safety, protect themselves and each other. Our challenge is to engage a broader team than just the “safety guy,” and we need to use audits as a forum for challenging facility management to fundamentally change the way they think about and manage safety. Audits are notoriously bad at doing this, because they fail to create an emotional response in the auditee. The goal is to create an atmosphere during the audit where all site employees feel personally responsible for conditions in the facility, and injuries that have occurred. If we can achieve this, then we have a chance of changing thinking and behavior, which will ultimately improve safety performance.

Expand employee involvement. Talk about commitment to injury prevention? You’ll know you have it when all members of the operational team are substantially involved and fully engaged in the audit process every day of the audit. Challenge the status-quo! Request that line-level employees be involved in the site tours each day. After all, they have a different insight than management and often are able to identify issues and behaviors that others don’t necessarily see. Also, consider asking a small team of employees to provide feedback on the current safety program or to assess the site’s compliance with a simple list of management system issues. Going through this exercise will help to build buy-in throughout the facility of the company’s commitment to meaningful safety performance improvements.

Focus on hazards. It’s not uncommon during closing meetings that when an unsafe condition that has no regulatory requirement is presented, the response is, “show me the regulation” and the ultimate response is, “no regulation, no finding!” When the discussion reveals that there is no regulation, just an unsafe condition, the issue is quickly dismissed as unimportant. Here is what I recommend — along with the list of regular compliance findings, consider keeping a second list of “other issues” that could cause injuries. This list should not be driven by regulation, but simply by their potential to cause an injury. This list is likely to be substantial and as it grows, has the potential to show facility management the error in their ways. They begin to feel responsible for the conditions in the facility, and the table is set for a change in behavior. And to be clear, this second list needs to be managed to a corrected and safe state, just like any other audit finding.

The Need for Change

EHS compliance audits have been occurring for years. My personal experience and the experience of other auditors has shown that good performance during a compliance audit is not necessarily an indicator of an operation’s ability to prevent injuries — over time, some operations have learned how to “audit” well! A colleague of mine likened an audit to a visit from the Mother-in-Law; We tidy up the house and prepare it for the visit, and soon after she leaves, the house goes right back to the disheveled mess that it usually is. The audit should be more like visiting a doctor; we know we have issues, we discuss them openly, and we develop strategies for resolving our issues.

Finally, in a world that is moving more toward sustainability every day, we owe it to our most sustainable resource — our employees — to perform better. Every injury is a chink in the sustainability armor. And let us not forget why we’re conducting audits in the first place: to more effectively prevent injuries. So I ask you safety leaders: If there is a way to get greater value and improved injury prevention, why wouldn’t we pursue it?

About the Author

Matthew J. Boardman, CSP, is a Senior Project Manager in the Rolling Meadows, Illinois, U.S.A. office of Environmental Resources Management. Mr. Boardman is an accomplished health and safety auditor, who has led and participated in hundreds of audits in a wide variety of industries and in several countries. Mr. Boardman is currently evaluating his ability to affect change during compliance audits.

Photograph: DayMarks by John Boyer, Abu Halifa, Kuwait.

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