Auditing for Safety Improvement

The mere thought of participating in an audit can be unnerving. Consider IRS audits for a moment – they can never mean good news, right? So why would an organization want to spend time, money and other resources to conduct an audit when it could be painful? The answer is that, regardless of the feelings they evoke, audits – when done right – can be a powerful organizational improvement tool rather than just a way to monitor compliance.

To better understand the importance of auditing for improvement, let’s review an example of a traditional compliance audit. In this example, the audit identified a distribution underground crew whose members did not use insulating cover-up while working inside a single-phase underground transformer. The apparent cause of the violation seemed straightforward – the crew members had simply failed to use appropriate insulating cover-up, so management reviewed the violation and mandated the crew to follow the rules in the future.

The action taken by management in this example seems acceptable, but was it truly enough? Will the apparent cause of this violation be completely remedied through talk and discipline? Although rule compliance is extremely important, audits that focus solely on this type of compliance may neglect to identify major gaps that contribute to an ineffective safety system. What happens if a utility doesn’t have the right people in place to support safety? For instance, it’s possible that workers have not been properly trained and frontline leaders don’t know how to apply the rules on a job site. In the previous example, the crew may not have understood how to use insulating cover-up on underground applications as they were only trained for application of cover-up on overhead lines.

Traditional compliance audits may miss the mark because many times they are focused on workers who are not working safely rather than the system that is not working effectively. Safety system deficiencies must be pinpointed in order for management to gain a greater understanding of how to improve the organizational safety process. Successful improvement involves analyzing the complete safety process, not just what appears on the surface.

Comprehensive Improvement Audits
A comprehensive improvement audit will dig into the entire safety process to identify gaps between an organization’s existing state of safety and its desired state. The desired state is generally determined by regulatory and industry best practices related to safety management systems, training systems and written rules and procedures.

Improvement audits are typically performed through a series of employee interviews, field observations and document reviews, all of which are designed to uncover weaknesses within work processes that enable unsafe conditions and contribute to worker error. Many audits include a safety perception survey and a common cause analysis. These tools can be used to identify specific safety culture issues or areas of vulnerability. They can also be used prior to an audit to identify specific focus areas that may need more attention during the auditing process. Let’s take a more in-depth look at both safety perception surveys and common cause analyses.

The Safety Perception Survey
In “Understanding Safety Culture Through Perception Surveys,” featured in the December 2015 issue of Incident Prevention (see www.incident-prevention.com/ip-articles/understanding-safety-culture-through-perception-surveys), we discussed the importance of using safety perception surveys to gain a true picture of worker perceptions of an organization’s safety process. These surveys are used to gather feedback from workers so management can gain a clearer understanding of actual working conditions and employee thoughts and opinions. Understanding how workers perceive safety can help identify specific focus areas to address during an improvement audit.

The Common Cause Analysis
A common cause analysis is used to identify if a single deficiency has caused multiple incidents. In other words, do multiple incidents have a common cause? A proper analysis includes reviewing existing data to determine areas of focused improvement that would yield the greatest sustainable positive results. This involves reviewing all available data related to recent events, close calls and survey results. When analyzed as a whole, this type of data can very accurately point to those areas of greatest vulnerability.

For example, a performance assessment was conducted at a fossil power plant because a significant number of incidents were occurring at the plant. A review of the event reports identified a high number of dropped loads from forklifts. To determine why so many loads had been dropped, training records were reviewed and interviews were conducted with people involved in the events. Talking to people was a critical part of this performance assessment. Interviews and a review of documents revealed that all forklift operators had been trained, but training had not included handling unwieldy or oddly shaped loads. Without a common cause analysis, improvement actions may very well have included retraining all the forklift operators with the same training they had already completed. After the analysis, the need to train forklift operators to properly handle unwieldy loads became evident.

Safety Management Systems
To better understand safety improvement audits, let’s now spend some time reviewing several typical audit components beyond safety perception surveys and common cause analyses.

Safety management system audits should address whether the safety process is appropriately monitored and managed. It is important to determine if safety oversight methods are effective in supporting the safety process. Safety success depends on leaders understanding their roles and monitoring, coaching and improving workers’ safety performance. A successful improvement audit will identify the effectiveness of leaders’ influence on workers’ behavior. Some basic questions that should be answered during the audit process include:
• Do leaders support the safety process and understand their role in safety?
• Do leaders actively participate in strengthening the safety process?
• Do leaders know rules and procedures and understand how to apply them to their job sites?
• Do leaders effectively monitor work activities to determine if workers are adhering to procedures, safety rules and management expectations?
• Do field observations detect deficiencies related to safe work rules?
• Do leaders effectively coach workers to correct unsafe or unacceptable work behaviors?

Although many compliance audits include a basic review of management systems, the focus, as stated earlier, may be on a frontline leader or other individual rather than the management system as a whole. Safety improvement efforts may not be effective by training or replacing a frontline leader. What if the frontline leader has no upper-level support or has not received effective coaching to support the safety process? It is important to review the overall management system to ensure sustainability for future safety efforts. An upcoming Incident Prevention article will review the safety management system and the importance of identifying and strengthening areas of vulnerability.

Training Systems
A review of training systems is another critical component of improvement audits. A training system audit should address whether current training is in alignment with how work is actually accomplished in the field. Earlier we cited an example about a distribution underground crew whose members didn’t use insulating cover-up while working inside a single-phase underground transformer. That example points to the importance of a training systems review. Workers may know protective cover-up rules but may not have a firm grasp on underground system hazards and how protective cover-up rules apply. Some basic questions that should be answered during the audit process include:
• Do training and qualification programs provide workers with sufficient knowledge and skills to safely work on equipment?
• Is an effective method in place to assess worker knowledge and skills?
• How do leaders ensure workers have adequate knowledge and skills before assigning work?

Written Rules and Procedures
A comprehensive audit should address whether rules, procedures and manuals provide adequate worker guidance regarding safety. Do current documents meet regulatory and consensus standard requirements? Additionally, it is important to determine how specific rules and procedures compare with best practices of other electric power organizations.

At a minimum, a review of each procedure should determine if the procedure is correct, how it is used and how often it is updated. For example, let’s say a utility required workers to review a procedure prior to removing a regulator from service due to a previous regulator incident. The procedure, which was documented in writing on the inside of the regulator control panels for ease of use, was faded and illegible. Also, the procedure had not been updated in several years and some substation equipment had been upgraded after the procedure was developed. Hopefully you agree this procedure was not useful to field workers and should be updated prior to future use. Procedures are only beneficial when they are current and used to improve a process. It is important to identify whether a procedure is a continuous use procedure, a reference use procedure, an information use procedure or a multiple use procedure. Each type of procedure is used differently, so it is necessary to understand when each would be appropriate for specific job tasks.

Developing a Sustainability Plan
The final step of an improvement audit is to develop a management report identifying safety process strengths and weaknesses. The report should prioritize improvements based on risk assessment methodology.

Once strengths and weaknesses are correctly identified and risk assessments are assigned, a strategic plan with short- and long-range improvement goals must be developed. Senior management should develop safety improvement plans because they are responsible for ensuring the safety process is effective and that appropriate resources are in place to meet future goals. Safety plans should be viewed with the same importance as other business plans, such as quality plans, productivity plans and profitability plans.

Although performing audits can be painful, the pain can be lessened when organizations use the information gained to make sustainable improvements to worker safety.

About the Authors: Kathy Ellsworth, CUSP, has more than 30 years of experience in the electric utility industry and has worked in transmission and delivery as well as nuclear generation. Ellsworth holds a degree in behavioral science and is experienced in safety, human performance improvement, training, and program assessments and audits.

Pam Tompkins, CSP, CUSP, is president and CEO of SET Solutions and a 37-year veteran of the electric utility industry. She is a founding member of the Utility Safety & Ops Leadership Network and presently serves on the executive board. Tompkins has authored and presented technical papers on high-voltage electrical safety issues at iP conferences, IEEE workshops, ASSE conferences and for many other organizations. She is an OSHA-authorized instructor who specializes in helping electric power organizations in the U.S. and abroad comply with today’s safety and training requirements.