Audits/Compliance

IVA/NSSTA >> COP PLATING/LABELLING AUDITS/COMPLIANCE APPLICATION PROCESS PREPARATION OBJECTIVES

Initial and Review Audits:
Organisations need to monitor their performance to assess how well they are controlling procedures, standards, conformity of productions and risk assessments.  A low incident rate is not necessarily a sign that all areas are being managed correctly, and so measures of performance need to be more wide ranging.

Measuring – objectives, standards, compliance and performance:
There is a saying that ‘you can’t manage what you can’t measure.’  It is clear that measuring is an important way of identifying where improvements are required and to prioritise action, thus keeping objectives, standards, compliance and performance at a premium level and over a constant time frame.

Active Measures:
Active measures give feedback about performance before incidents are experienced. Obviously this is preferable, allowing for suitable preventative actions can be taken.  An additional benefit is that active monitoring measures success and reinforces positive achievement.
Active measures usually consider the following:
•    Achievement of specific plans, procedures and objectives;
•    Operation of a management system;
•    Compliance with standards and procedures;
•    Site condition inspection;
•    Environmental monitoring;
•    Health & Safety surveillance;
•    Behavioural observation.

Reactive Measures:
Reactive measures are triggered by events including:
•    Injuries;
•    Ill health;
•    Property damage / loss of sales;
•    Incidents with potential to cause harm (directly or indirectly);
•    Hazard reports;
•    Complaints.

Inspections:
Inspections regarding approvals generally involve looking for physical evidence of how well procedures and conformity of productions (COP) are being managed / implemented and often are a requirement by the relevant legislation pertaining to area / section being inspected.

The people carrying out inspections need to be suitably competent, and will usually use some form of inspection checklist.  To be effective, inspections need to be planned properly, carried out at a suitable frequency, record suitable remedial actions and not be restricted to the specific items but used as an opportunity to make general observations (e.g. house- keeping and cleanliness).

Results of inspections need to be reviewed periodically to identify any common features and trends.  Also, the frequency of inspection may need to be varied, depending on previous findings.

 Audit:
An audit is a formalised method of investigating a system’s performance.  It is the structured process of collecting independent information on the efficiency, effectiveness and reliability of a system and the drawing up of plans for corrective action.

There are two main types of audit.
1). A ‘systems audit’ checks that necessary systems are in place, comply with legislation, guidance and good practice and are generally appropriate for the approval gained.
2). A ‘compliance audit’ checks that the systems are being used and result in appropriate workplace precautions.

An audit cannot look at every element of a system, and so sampling is important. Some elements need to be checked more often than others, and it is bad practice simply to do the same audit every time.  A useful concept is the idea of ‘vertical’ and ‘horizontal’ audits.  A vertical audit takes a subject and sees how it fits into all elements of the approval process (i.e. how it is covered by policy, organisation, arrangements, measurement, audit and review).  A horizontal audit selects one part of the system and considers how different items are addressed.

Any auditor should be able to act independently, so it is not normal for someone to audit their own system or compliance.  However, internal audits can be carried out, typically by people from a different department from that being audited.  These audits can be particularly useful at sharing best practice and learning through an organisation, and the auditors usually have the benefit of knowing the systems very well, including known weaknesses (i.e. they know where to look for problems).

To ensure an audit system remains relevant it is usually necessary to carry out some degree of external auditing.  This is a requirement for achieving defined standards and is normally conducted by the approval / certification authority that has issued the approval, standard.

Auditing is not always as successful as it should be and there have been examples of where companies have had major non conformances after audits have been conducted and signed off. Part of the problem is that organisations get to know what they are going to be audited on, and make changes to do well in the audit.  This can be at the expense of other items that are more critical but not covered by the audit.  For this reason it is better that all auditors use their agreed schedule as a guide, whilst taking every opportunity to fully explore all aspects of the system / approval.

Driving Improvement:
Of course it is no good collecting information if nothing is done with it to correct deficiencies.  Organisations need to review the information they have from all sources and act on it.

 Setting Targets:
Setting targets can help improve performance by giving people something tangible to aim for and also demonstrate that the organisation is serious about the issue. It is better to set targets that will result in positive outcomes.
Examples may be:
•    Completing inspections and audits as per an agreed schedule;
•    Implementing recommendations within a specified time scale;
•    Staff training;
•   Achieving recognised standards.