By Cameron Clark
Has there been a more famous food safety message than Seinfeld’s ‘Double Dip’ episode? Perhaps not, but that same message can also apply to safety audits. I’m not talking about food hygiene, but how the outcomes and findings from your safety audits are employed to best support you and the auditee. There’s limited value in issuing two nonconformances for the same poor performance without proper justification.
There are many examples in an organization’s health and safety execution (both good and bad) that contribute to performance in one or more audit criteria. The challenge for the auditor is to determine the contributing factors so that the findings can be presented in a manner that best supports continual improvement in the system and, as a result, the auditee. Hitting an auditee with two nonconformances simply because it’s possible, rather than because its justified, says more about you as an auditor than you may want to convey.
Consider safety audits assessing an organization’s training program. The absence of training records could mean that there was no training program, or it could mean that there weren’t sufficient resources to complete the training, that the responsibility for completing the training hadn’t been effectively allocated, or it could mean that records of training simply weren’t kept. Simply applying a nonconformance across one of more criteria related to training, record keeping or criteria related to responsibilities or resources only places the onus on the auditee to determine why there weren’t any records of completed training.
To rectify, does the auditee provide additional training resources or ensure that those responsible for training are aware of them? None of these actions will improve performance if the issue relates to record keeping. The efforts wasted trying to address non-existent issues reduces your value and reputation as an auditor and further contributes to an increasingly sceptical attitude towards audits of any kind.
As an auditor your efforts shouldn’t stop once the gap is found but should continue to understand why the gap is present. Interviews with the workforce could easily verify whether or not a training program existed and whether or not time was made available for them to attend. Equally, if the issue is with record keeping, training records are unlikely to be the only records missing. By understanding why any gap is present, an auditor is better able to evaluate whether or not a requirement is being fulfilled or not.
This doesn’t limit you issuing multiple nonconformances if there are multiple reasons for a systematic breakdown in the management system but ensure that the objective evidence supports your audit findings.
As independent auditors, you sometimes also have to support your clients against over enthusiastic regulators who are often eager to “double dip the chip” in order to demonstrate the need for more drastic improvements. During an internal audit an incorrect fire extinguisher type was identified that resulted in a nonconformance against criteria related to the suitability of fire and emergency equipment. The audit report was provided by the client to the regulator as part of special licence conditions, however the regulator considered that the evidence of unsuitable fire extinguishers should also have resulted in nonconformances being issued against criteria related to plant and equipment maintenance as well as the organizations monitoring and inspection program. Without investigating further, the regulator had used their own unconscious bias to associate poor performance in one criterion with a systematic breakdown in other parts of the management system. The auditor, who had developed a keen understanding of why the issue had occurred, was able to walk the regulator back and reduce the need for unnecessary corrective actions.
Such an approach has multiple benefits for both auditor and auditee. Most importantly its more likely that your findings will be accepted, and even welcomed, by the auditee because they are meaningful and address specific issues. Where findings are accepted its far more likely that the auditee will develop effective corrective actions that better address the non-conformance, rather than something that is a low effort fix that simply papers over the real issues.
About the author
Cameron Clark is a health and safety professional with more than 17 years’ experience providing OHS consulting and auditing services to a range of large multinational organizations. He is currently a founder and Managing Director of Verus Australia and an Exemplar Global-certified Lead OHS Management Systems Auditor. Cameron can be contacted via firstname.lastname@example.org or via www.verus.com.au.