Management System Auditing Criteria

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Bureau of Safety and Environmental Enforcement SafetyManagement System Auditing Criteria and Checklist

Introduction

Safety Management System Auditing Criteria and checklist was requested to be provided by the Bureauof Safety and Environmental Enforcement (BSEE) as part of the contract to develop an example SafetyManagement System (SMS) for a hypothetical wind farm.The purpose of the SMS Audit Program is to provide a systematic assessment of the consistent andeffective implementation of the SMS and to confirm that the SMS itself meets BSEE expectations.

Auditees should ensure that potential or actual weaknesses in the SMS, or in its implementation,identified in the audit are remedied through effective follow up of the audit findings and assure compliancewith applicable laws and regulations.

Audit team Competency

Personnel assigned to carry out audits will have sufficient experience, knowledge or training of thestandards applied and lease owner specific requirements to enable proper examination of the activities tobe carried out. He/she will also have had completed an internal auditor training course to demonstratethat an acceptable level of understanding has been achieved. Auditors should have 3 years EHS workexperience or 5 years of operational work experience, and be proficient in the core competencies oftechnical, analytical, and communications (interviewing).

Reporting and Documentation of Audit

SMS audits conducted by BSEE will assess the scope, content and effectiveness of implementation ofthe local SMS assessed against 30 CFR 585.10. The audit shall cover SMS aspects of the company orlocation and interfaces with authorities, contractors (e.g. maintenance, projects, waste), customers, and

the public. All elements of the SMS will be assessed to assure that they comply with BSEE guidelines andare fit for purpose. A key element will be verification that an adequate internal audit system is beingoperated. Special key programs will be assessed for compliance with regulations, permits and/orstandards.

SMS documents, files and records will be reviewed as well as interviews of personnel at facility/businessto verify implementation of the management system and associated procedures.

The Auditor(s) will examine objective evidence to establish compliance and identify potential areas forimprovement. The audits conducted will examine the company SMS against 30 CFR 585.810 whichspecifically requires the following:

a) How you will ensure the safety of personnel or anyone on or near your facilities;

b) Remote monitoring, control, and shut down capabilities;

c) Emergency response procedures;

d) Fire suppression equipment, if needed;

e) How and when you will test your Safety Management System; and

f) How you will ensure personnel who operate your facilities are properly trained.


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The auditor will note observations made when carrying out the audit on the "Audit Checklist" makingreference to the appropriate procedure or process.

All non-conformities identified are recorded on corrective action reports to establish root cause(s) andcorrective actions required to prevent recurrence. Corrective actions will address systemic errors.Timescales are to be agreed between the auditee and the auditor.

The auditor will assess the defined corrective action through to satisfactory conclusion. Evidence offollow up is recorded on the corrective action request and observation sheet as appropriate.

All audit records will be retained.

General Expectations and Corrective Actions

At the conclusion of the each SMS audit a draft report identifying the audit findings and noteworthy effortswill be prepared. The Findings should begin with an opening statement that is the bottom-line message.The finding statement should be supported by observations and/or examples of facts. Provide theregulatory citation or reference to company standard to the lowest level of detail possible. Either quote orbriefly paraphrase the part of the requirement that shows a clear link to the observed non-conformance.

Provide a recommendation that incorporates systematic processes that will prevent reoccurrence.

Corrective action must be taken to address the findings if applicable. Within 30 calendar days from thedate of the closing conference, the auditee should develop a Detailed Corrective Action Plan (CAP) forall findings. Actions resulting from Findings identified during the must be tracked to completion.


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a) How you will ensure the safety of personnel or anyone on or near your facilities

Health and Safety Policy Check if yesSection of SMSwhere located

Comments

Does the organization have a health andsafety policy statement that is clear andunambiguous?

Does it make a clear commitment tomeeting all relevant and currentstandards?

Does it make a clear commitment tocontinually improving standards?

Has the head of the organization signedthe policy?

Is there a commitment to review the policyand keep it up to date?

Is there evidence that the policy has beenreviewed within the specified time frame?

Organization, Roles and Responsibilities Check if yesSection of SMSwhere located

Comments

Is there evidence that health and safetyrole and responsibilities are delegated toappropriate levels in the organization?

Has a senior member of the managementteam been designated to lead on healthand safety?

Is there a clear organizational structurethat is capable of implementing the healthand safety responsibilities of theorganization?

Is it stated that appropriate resources willbe utilized?


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Communication Check if yesSection of SMSwhere located

Comments

Is there a process to communicate healthand safety information to relevant staff?

Are there criteria setting out when andhow managers are expected to formallydiscuss health and safety matters withtheir staff?

Is there evidence that tool box talks occurregularly and that a H&S committeeexists?

Hazard Identification and RiskManagement

Check if yesSection of SMSwhere located

Comments

Are there systems in place to identifyhazards and assess risk in theorganization?

Is there evidence that hazards areidentified and risk assessed throughoutthe organization?

Is there evidence that the risk assessmentprocess feeds into control measures andsafe systems of work?

Are there systems in place to monitor theeffectiveness of the controls?

Is there evidence that the effectiveness ofthe controls is monitored?

Is there evidence that risks identified areinfluential during the making of keydecisions at senior management level?

Management of Change Check if yesSection of SMSwhere located

Comments

Is there evidence that changes in healthand safety information are identified andcommunicated to relevant staff?


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Is there evidence of documentation ofcommunication of change?

Safe Work Practices Check if yesSection of SMSwhere located

Comments

Are safe work practice procedures outlinedin the SMS?

Is there evidence that other documentscover the work procedure in a thoroughand simple manner?

Environmental Management Check if yesSection of SMSwhere located

Comments

Is there a separate document that outlinesthe policies and procedures that outlinemanagement of permitting and spills?

Measuring Performance Check if yesSection of SMSwhere located

Comments

Does the organization have keyperformance indicators (KPIs) for healthand safety performance?

Is there evidence that KPIs are used toimprove health and safety performance?

Is there evidence of bench markingperformance?

Is there evidence of reactive monitoring ofhealth and safety performance?

Is there evidence of pro-active monitoringof health and safety performance?

Is there evidence that deficiencies inarrangements identified by monitoring areacted on?


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Are work related health trends monitored?

b) Remote monitoring, control and shutdown capabilities

Check if yesSection of SMSwhere located

Comments

Is there a description of how the wind farmwill be operated remotely and provisionsfor control and shutdown procedures?

c ) Emergency response procedures

Is there a section of the SMS thatdescribes the emergency responseprocedure?

Is search and rescue referred to and isthere evidence of a second, separateprocedure that was developed inconjunction with the USCG?

d) Fire suppression equipment, if needed

Is there a description of any firesuppression equipment located on theturbines and substations?

e) How and when you will test your SMS

Reviewing and Auditing Check if yesSection of SMSwhere located

Comments

Are there arrangements for reviewing theorganizations health and safety policy?

Are there arrangements for reviewing theorganizations health and safetyperformance?


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Is there evidence that senior managersreview the health and safety performanceof the organization?

Is there evidence that the review feeds

into future plans and strategies?

Is there evidence that a review of anindividuals performance includesconsideration of their health and safetyperformance?

Are there arrangements for reviewing theadequacy of the health and safetyorganizational structure?

Are there arrangements for reviewing theadequacy of the health and safetyplanning arrangements?

Are there arrangements for reviewing theadequacy of the implementation of healthand safety policies and procedures?

Are there arrangements for reviewing theadequacy of the measuring/monitoring ofperformance arrangements?

Are there arrangements for reviewing theadequacy of the organizations health andsafety audit arrangements?

f) How you will ensure personnel who operate your facilities are properly trained

Training and Competence Check if yesSection of SMSwhere located

Comments

Are health and safety competenciesidentified and built into job profiles?

Is there evidence that health and safetytraining needs are being identified andmet?


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Is there evidence that health and safetytraining outcomes are evaluated?

Is there evidence that the requirements forinformation, instruction and training are

being met?

Are records of individualtraining/competency held?

Documents

Management System Auditing Criteria