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Patty's Industrial Hygiene, Program Management and Specialty Areas of Practice


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can also help identify deficiencies in the facilities internal auditing practices. It is effective to identify an on‐site coordinator who will act as the key liaison between the facility and the audit team and can facilitate scheduling and logistics for the team.

      The preaudit questionnaire also serves an important internal function. The act of collecting data, gathering policies and procedures, and completing preaudit forms is an educational process for both the on‐site coordinator and the individuals gathering the documents. Even before the audit team arrives on site, the coordinator will usually have a good estimate of the facility's overall compliance or conformance with the areas or issues within the audit scope, from examining the general pattern of responses to items on the questionnaire, there is value in seeing this at the early stages of the audit. The preaudit questionnaire also provides the opportunity for senior management to see what may be ultimately included in the final report. Finally, for issues with significant risks, this provides an opportunity to take immediate action.

      A memo from senior management to key site personnel prior to the audit emphasizing their need to cooperate and participate can help make the on‐site activities proceed smoothly.

      During preaudit activities, the lead auditor should ask the site contact to ensure that sufficient on‐site working space and resources are provided for the audit team. This includes a conference room or office of sufficient size, telephone, internet access, photocopying support, and document access. Bringing in meals should be considered to increase efficiencies

      Before arriving on‐site, there should be an understanding of any site‐specific security, security‐clearance, PPE, or OH&S training needs.

      8.4 On‐Site Activities

      8.4.1 Opening Meeting

      A management system audit normally commences with an opening meeting during which the audit team presents details of the on‐site and postaudit activities, including the intended scope, time frame, progress report/meeting frequency, format of draft and final report, and method of delivery. This is also an excellent opportunity for the team to raise any issues from the preaudit questionnaire that need further clarification. Methods of communication and preferred communication channels are typically reviewed.

      Typically, the site management takes this opportunity to provide an overview of the site's operation and describe any aspects of the programs and systems that may not have been included in the preaudit questionnaire or preaudit discussions. The opening meeting is frequently followed by a preliminary tour of the facility, often led by operations and site OH&S personnel. The tour enables the auditor(s) to ask any additional questions in light of the preaudit questionnaire and the opening conference, as well as identify areas to which they want to return later in greater depth. At the conclusion of the tour, the audit team usually meets alone, briefly, to draw up a specific plan for how the scope of the audit will be covered in the time specified. If there is a need for company representatives to escort audit team members, ensure at this early stage that there are enough representatives if the audit team is large.

      It is important at this time to work with site personnel to identify key individuals the team is interested in interviewing in depth to ensure these personnel will be available.

      8.4.2 During the Audit

      The remainder of the on‐site activities involves interviewing site personnel, reviewing documentation and records, and revisiting site areas to verify what the audit team is learning. Audit teams may choose to conduct daily briefings to update site personnel of their observations and provide a forum to resolve any misinterpretations immediately. These daily gatherings help to make the official close‐out meeting run more smoothly by avoiding findings that may result from miscommunication rather than actual deficiencies.

      During the audit, auditors should immediately bring to the attention of the site coordinator any observed life‐threatening or high‐risk issues.

      An important component of an audit is conducting interviews with site personnel. Auditors should have training in how to conduct effective interviews. Interviews should be structured so that the interviewee can be open and honest without concern about potential retribution. The audit team should be involved with the selection of who will be interviewed to make sure that there is no potential bias. Beyond key managers and persons with OH&S accountabilities, selection of interviewees should be done randomly. Interviews are typically conducted alone between the auditor and interviewee, and management representative participation should be discouraged. In some cases, union contracts require a labor representative to be present when employees are interviewed.

      At the conclusion of each day, the audit team should meet to discuss findings and the observations of each team member. Corroboration of objective evidence happens at this point. Each day, the lead auditor should assemble the audit finding from that day. This will help avoid a rush of work on the last day on site, and allows for discussion with site personnel about findings as they come up. As issues come up that may be out of a team member's area of expertise, the issue should be reexamined the next day by a qualified team member.

      8.4.3 Closing Meeting

      At the conclusion of the audit, a closing meeting is typically scheduled to discuss the audit findings and to answer any unresolved questions or issues. This meeting should be chaired by the lead auditor. Ideally, the most senior manager of the site should be present at this meeting to ensure the findings are presented to the individual most able to affect change. During the closing meeting, a date should be determined for the delivery of the draft and final reports. The closing meeting should be structured to provide upper management with a concise summary of critical issues that require immediate action. When the major items are presented in an abbreviated and prioritized format, senior management can make important resource allocation decisions well in advance of receiving a written report.

      A goal for the audit team should be that there are “no surprises” at the closing meeting and hence in the written final report. Audit observations that lead to audit findings should be reviewed daily with site personnel when they arise.

      8.5 Audit Report

      While all audit team members have input into the audit report, the final report is typically written by the lead auditor. The report should include the audit objective and scope, and list the site areas included. It may be appropriate to include the initial audit plan and lists of people who attended opening and closing meetings.

      A different report style can list both the elements that were found to be in compliance and the deficient areas. This format can alert management to all of the problems, while at the same time providing information on the positive aspects that are being handled well by the employees. Therefore, areas in need of attention are denoted at the same time that recognition is given for items that do reduce risks. This type of report can provide senior management with a good overall perspective of facility status.

      Still another report type may state only a recommended course of action based on the observations made during the facility