No matter how it gets presented, when the corporate auditors arrive to “help you improve,” it more often than not feels like a one-sided battle. Dozens of audit findings to correct, explanations of how you could let this happen, presentations in front of the plant manager … the list goes on. It makes you tired and anxious just thinking about it, doesn’t it? And OSHA VPP and PSM sites end up with even more than the normal number of safety audits. It’s sort of a necessary evil in this profession, and it fundamentally is a thankless process.
There is hope: In our little corner of the world, our audit process is changing dramatically and, believe it or not, is becoming an event that plant managers and site-level safety professionals welcome and for which they thankful.
At our company, Laura Denos, an EHS manager who has worked at a Fortune 500 company, was instrumental in this transformation. Over the years, I’ve had the opportunity to work with Laura on several audits, including some she conducted at my site. We are both VPP special government employees, and have spent many hours in preparing our own sites and helping other sites prepare for the VPP process.
We understand the need to improve our audit processes to include the key elements that make a site a VPP Starlevel performer. We have continued to change and improve our process to the point that now we receive genuine thank-you notes from plant managers upon completion of our audits.
As we all know, the typical audit follows the “seagull” pattern where the auditor flies in, drops a bunch of findings on the site and then heads out. Laura, working with several of our site’s EHS leaders, has used the Lean Kaizen (continuous improvement) approach and has modified our auditing technique several times. It now includes the key value-add elements that are listed below. These elements all can be incorporated in your audit process, or you can pick and choose what you like.
So here are some suggestions, from our experience, that you may want to try:
➤ Physical walkthrough: Conduct a “wall-to-wall” inspection, going into the dark corners of the facility looking for compliance issues. Have someone from the site with you to let maintenance know about issues as you find them. The expectation is that they immediately will fix any compliance issues if possible (we call this “find it/fix it”). You can explain what makes it regulatory or non-regulatory and use this as a teaching moment. Take before and after pictures to use at report-outs.
➤ Stop @ five: When looking at a specific safety topic (e.g., fire extinguishers, electrical panels, emergency lighting, etc.) once you find five of the same violation, STOP, and move on to the next topic. Let site personnel know that they may have a systemic problem that needs to be addressed. Document a systemic finding and move on.
➤ Document review: This always is important. Start with “high risk” and make sure the documented process aligns with the actual activities of the shop floor. This helps you match up your “say-do” relationship.
➤ Formal interviews: Styled after the VPP audits, randomly select a handful of employees to bring in for a sit-down interview. This will provide candid feedback for the plant manager and his staff about the site’s safety culture as seen from the employee’s point of view.
➤ Informal interviews: While on the shop floor, audit team members need to take the time to stop and talk with employees. Plant personnel walking around with the auditor should step back and allow the auditor to talk alone with the employee. In an informal manner, ask two or three openended questions and look for trends and opinions about the safety culture.
➤ Employee engagement: The most effective safety programs are those that are spread throughout the operation. There should be many owners for safety responsibilities and there should be evidence that it’s not all on the shoulders of the safety professional or department.
➤ Coaching and mentoring: Never miss the opportunity to coach and mentor. Pull together the maintenance teams and discuss electrical compliance or high-hazard work. Meet with safety teams to discuss issues and solutions. Help them feel empowered to do what they are allowed to do to fix safety concerns.
➤ Action work outs on specific topics: Take one or more identified safety or ergo issues and pull together an adhoc team to brainstorm ideas and implement solutions. Use problem-solving tools like “5 Whys?” and “7 Ways” to come up with possible solutions. Anything that is fixed during the audit week helps build confidence in team members that issues can be resolved and turns skeptics into believers.
➤ Completion of site-required audits: If the site is on the hook to complete internal self-audits, see if your audit team can help complete them and even load them in the site’s computer tracking system if needed. This can be a real value-add for resource- strapped sites.
➤ Compliance “quick-hour” training: Develop a 1-hour training module jam-packed with information about compliance issues and hazard recognition. Teach it to as many salaried and hourly employees as possible while you are there to help them understand why findings are considered compliance or non-compliance. If you follow these suggestions when engaging in the audit process, you will find that you not only receive greater benefits from the audits, but you might even look forward to audits as a way to fine-tune your safety culture and process.
There are ways to improve and expand the audit process so that at the end of the day, we are all getting what we really need – risk reduction or elimination. Our goal as safety professionals is, of course, prevention, and the clever techniques and elements you now incorporate into the audit process will take us closer to the ultimate goal for regulatory compliance: Nobody gets hurt.
Bob Edwards graduated from Tennessee Technological University as a mechanical engineer in 1989. He has worked in product design, technical support and maintenance leadership roles. Seven years ago, he became the safety leader at a large appliance manufacturing plant in Georgia. He has taken his broad-based experience and applied it to the world of health and safety and has developed many creative solutions for his site and factories that he has mentored. Edwards also is a VPP special government employee and assists with Region IV VPP audits and with SGE classes taught in the Region IV area.
Laura Denos graduated from Illinois State University in 2003 with a masters degree in environmental health and safety. She also has a bachelor’s degree in applied health science from Bowling Green State University. She has worked for General Electric and Cooper B-Line as an EHS manager at several facilities across the country. Her forte is in manufacturing turn-arounds; helping to educate and develop struggling health and safety programs and turn them into centers of excellence. She led one of her facilities to VPP star status in 2009. She also received her VPP special government employee certification in 2010.
(The views expressed in this article do not necessarily represent those of General Electric, nor is the content of this article an official statement or position of the General Electric Co.)