Learning outcomes

4.1 Outline the difference between active and reactive monitoring and the
purpose of active and reactive monitoring methods.

4.2 Explain the purpose of, and procedures for, investigating incidents and the
requirement for recording and reporting accidents, cases of work-related ill-
health and other occurrences.

4.3 Describe the purpose of, and procedures, for health and safety auditing.

4.4 Explain the purpose of, and procedures for, regular reviews of health and
safety performance.
 4.1 ACTIVE AND REACTIVE MONITORING
Monitoring of Performance Standards
This is an essential part of any health and safety programme. In any business or occupation there has to
be a system of checking that allows the stakeholders to measure how well they are doing. In health and
safety, this may consist of determining the failure of the system from safety statistics such as the
Reporting of Injuries, Diseases and Dangerous Occurrences as well as the first-aid cases reported and so
on. Similarly, investigations of accidents are a means of monitoring, since they determine why a system
has failed to prevent an accident. Monitoring may also include checking whether the system itself is
actually working or not. Monitoring describes a range of methods used by organisations to assess how
effectively they are controlling risks and how well they are developing a positive health and safety
culture. Companies should monitor their performance in managing health and safety in the same way
that any other aspect of business is monitored. The reasons for this are that it will enable the
organisation to:
 Identify substandard Health and Safety practices
 Identify trends
 Compare actual performance against targets
 Benchmark
 Identify use and effectiveness of control measures
 Make decisions on suitable remedial measures
 Set priorities and establish realistic timescales
 Assess compliance with legal requirements
 Provide information to Board, committees etc.

Systematic Inspections
One popular way to actively monitor health and safety performance is to carry out systematic
inspections. These inspections can focus on the four Ps:
 Plant – machinery and vehicles, as well as any statutory
inspections and examinations.
 Premises – the workplace and the working environment.
 People – working methods and behaviour.
 Procedures – safe systems of work, method statements, permits-
to-work, etc.
An inspection might concentrate on one, several or all four of these
areas. Systematic inspection regimes usually exist in many different
forms within different workplaces.
For example, in a distribution warehouse there might be:
 A daily inspection regime, where forklift-truck drivers inspect their own vehicles at the start of
each shift – Plant.
 A weekly inspection regime, where supervisors check that forklift trucks are being driven safely –
People.
  A monthly inspection regime, where the manager checks the entire warehouse for housekeeping
– Premises.
 A six-monthly thorough examination of each forklift truck by a competent engineer to ensure
safety of the load-bearing parts – Plant.
 An annual inspection regime for the storage racking to ensure structural integrity – Premises.
If this series of inspections is in place then it is possible to monitor the degree to which each is being
carried out successfully. In this way, two different types of active monitoring are being carried out: one
on the workplace directly (the four Ps), and one on the performance of those checks.
Role of safety inspections
A safety inspection involves the simple observation of a workplace and/ or the activities or equipment
within it. It is usually carried out by a manager, employee representative and Safety Advisor & typically
helped by the usage of a checklist, may be performed consistently & has the goal of recognizing hazards
& assessing the implementation & efficiency of control steps.

Limitations of Safety Inspections:

 It is only a snapshot in time
 Some hazards are not visible
 Some risks may not be present during the inspection and may occur later in the process
 Unsafe practices may not happen during the inspection if the employees know the inspection is
taking place

Types of Inspection
There are many types of inspection but the two most common are:
 General workplace inspections carried by management, health and safety representatives,
safety practitioners on a regular basis
 Statutory inspections which are required by the country’s legal system and is made by a
competent person. Most countries will have a requirement for cranes to be inspected every year.

Frequency of Inspections
Factors to take into account when determining the frequency of inspections:
 Statutory requirements may dictate an inspection frequency.
 The activities carried out and the level of risk.
 How well established the process is, e.g. new equipment may require more frequent monitoring.
 Risk assessments may suggest inspections as a control measure.
 Manufacturers may make recommendations in relation to inspection frequency and content.
 The presence of vulnerable workers, e.g. young and inexperienced people.
 Findings from previous inspections, which may suggest compliance concerns.
 Accident history and results of investigations.
 Enforcement authorities may recommend inspections.
 Whether workers have voiced concerns.
Factors to be considered prior to the inspection are:
Certain factors must be considered before a workplace inspection system is introduced, including:

The type of inspection – inspections are carried out for a number of different reasons and they
examine different aspects of safety in the workplace. Is this a statutory inspection to ensure legal
compliance? A general workplace inspection that looks at plant and premises? A pre-start inspection for
an item of machinery?
The frequency of inspection – It is likely to be determined both by the type of inspection and the level
of risk. For example, a general workplace inspection might be conducted in an office once a month, but
once a week in a workshop environment to reflect the higher risk. The frequency of statutory
inspections is normally determined by the relevant law. Pre-start checks should usually be carried out at
the start of every shift.
Allocation of responsibilities – those responsible for ensuring that inspections take place should be
identified, as should the employees who will be carrying out the inspections.
The competence and objectivity of the inspector – an essential characteristic of whoever is
conducting the inspection; the person should have the necessary training, knowledge and experience. In
some instances, certification to a specific standard will be required. In other
situations all that are necessary is an understanding of the workplace,
health and safety principles, and a willingness to ask questions. An
inspector also needs to be impartial and objective in their approach,
even when looking at an area that they are very familiar with.
Training may be required for those who will be conducting
inspections.
The use of checklists – these are valuable tools for use during the
inspection process. Checklists ensure that:
 All points are covered by the inspector.
 There is a consistency of approach to the process.
 There is a form of written record of the inspection and its
findings.
However, checklists do have their weaknesses, the most important being that an inspector might only
deal with the points on the checklist and ignore other issues that exist in the workplace but are not
included on the checklist.
Action planning for problems found – so that appropriate action is taken following the inspection to
resolve issues in a timely manner. An inspection system that identifies a problem or issue but then does
not result in action being taken is a flawed system. There must be clear identification of the:
 Corrective action required.
 Persons responsible for taking that action.
 Priorities/timescales.
The inspection system can be documented and formalised once procedures based on all these factors
have been agreed upon.
Inspection Checklists
In many situations the use of a pre-prepared checklist of topics may be useful as a memory aid and to
prompt the inspector into examining the appropriate areas. A checklist might include various points
under headings such as:
 Housekeeping
 Electrical Safety
 Provision and use of PPE
 Utilization and storage of Hazardous Substances
 Manual Handling
 Traffic Routes
 Emergency Equipment
 Welfare Facilities

Use of checklists

Strengths Weaknesses
 Enables prior preparation and planning  Over reliance on checklists may result in a
 Inspection is more structured and blinkered approach by inspectors
systematic  Checklist may not be reviewed/updated
 Reduces the chance of significant issues to account for changes
being overlooked  Inspections might become routine with
 Provides immediate record of finding no follow-up questions being asked
 Ensures a consistent approach  No scope for peripheral issues to be
 Provides easy method for comparison considered
and audit

Allocation of Responsibilities & Priorities for Action

It depends on the level of risk and any statutory inspection requirement. Directors may be expected to
examine the premises formally at an annual audit, whereas departmental supervisors may be supposed
to carry out inspection every week. Senior managers should regularly monitor the health and safety plan
to ensure that objectives are being met and to make any changes to the plan as necessary. Data from
reactive monitoring should be considered by senior managers at least once a month. In most
organizations serious events would be closely monitored as they happen.

Report Writing
There are three main aims to the writing of reports and they are all about proper communication. The
purpose of the report must be to:
 Convey the message to the reader
 Clearly present the message and arguments, so that they are easy to understand
 Persuade the reader to take actions by making the arguments and conclusions convincing.

Five important factors which will help to make reports useful are:
 Structure
  Presentation of arguments
 Style
 Presentation of data’s
 Report formatting & presentation

Inspection reports should not only be a list of things that are wrong. Inspection reports should:
 List the good points as well as the hazards. This will make the receiver feel that the statement is
fair.
 Identify actions to eliminate or control hazards and also to prevent them from occurring again.
 Prioritise the measures to be taken and set time limits and specify responsibilities to carry out
the actions and also set review dates.
 Be structured, summarising the key issues, and placing emphasis on the need for action and
kept as short as possible.

The Target Audience

Once the purpose of the report has been determined, the next most important consideration is the
intended target audience. The reasons for needing to know the target audience are mainly concerned
with the way that the report is to be written. For example, the considerations will include:
 Style - how formal or otherwise the report needs to be
 Language - whether it is written for an informed reader or not
 Function

The Content of a Report

Most reports should have a common general structure which is most likely to comprise of (in this order):
 Administration information
 Introduction
 Summary
 The body of the report
 Conclusions and recommendations
 Appendices

Sampling, Surveys and Tours

Safety Sampling
It is an observation/inspection activity where a representative sample of work tasks, areas, equipment
and/or people are studied to check health and safety conditions and practices e.g. to see the use of
hearing protection. It notes compliances and non-compliances which are counted to provide a score of
the overall effectiveness of safety performance. Sampling is where only a partial amount of a particular
area is looked at to establish an indication of the standard of compliance as a whole. For example a
random inspection of some pieces of lifting tackle could indicate the general standard.
Safety Survey
A safety survey is a detailed examination of one particular issue or topic, e.g. a detailed examination of
the provision of emergency lighting within a building. The word “survey” can be used to refer to various
types of detailed examination:
 Environmental monitoring is a form of safety survey, e.g. a noise assessment usually requires
that a noise survey is carried out by a competent person using a sound-level meter.
 A structural survey is a detailed examination of the structural integrity of a building or item.
 A staff survey is an examination of workers’ opinions, usually collected by asking staff to fill in a
questionnaire.
All of these types of survey might be used to actively monitor safety.

Safety Tour
A safety tour is a high-profile inspection of a workplace carried out by a group or team, including
managers. The tour may be formal, but can also be informal - a walk around looking at points of interest
(usually unscheduled). The group carrying out the tour should include managers from the area being
inspected and possibly worker representatives, safety specialists, occupational health specialists,
engineers and workers from the area. One of the objectives of the tour is to raise the profile of health
and safety and to demonstrate management interest and commitment. Safety observation tours can
also be used to monitor the way that workers are behaving – these are known as behavioural
observations. Once behaviours are observed, feedback (positive and negative) is given to the worker so
that the organisation and operator can learn from the process..

Reactive Monitoring Methods

The means of obtaining a picture of the current state of the organisation is by reviewing what has
already happened, otherwise known as reactive measures. The main means of obtaining this
information is by reviewing information recorded as part of the health and safety management system.
There are a range of reactive measures that can be utilised for the purpose of monitoring. These include
reviewing data relating to:
 Enforcement actions
 Injuries or ill health, including sickness/absence
 Complaints from workers
 Damage to property, goods or equipment
 Dangerous occurrences
 Near misses

Reactive monitoring involves:

 Investigating accident/incident
 Creating and compiling data and statistics
 Identification of immediate and underlying causes and preparation of report

Accident Statistics
Statistics can show trends, highlight problem departments and activities, show demographics of
accidents for example, the total number of accidents in a year broken down into various categories or
severity of
 injury, type of accident, job titles of persons suffering accidents, accidents in each department or
location, etc. depending on the requirements of the company. It also allows for comparisons between
organisations/units.

Limitations of accident statistics

Some problems with Accident, injury/ill health statistics:
 Incidents may get unreported, due to a poor reporting culture.
 An event resulting in an injury could be a matter of chance, and it may not always indicate that
the hazards are well controlled.
 Potential severity of an event may not be assessed by injury rates.
 There is enough evidence to show there is not necessarily a relationship between ‘occupational’
injury statistics (e.g. slips, trip and falls) and control of the main accident hazards (e.g. loss of
containment of toxic or flammable material).
 A sense of complacency could set in, when there is a low level of injury rates.
 Injury statistics reflect outcomes not causes.

Lessons Learnt
Learning lessons from incidents and accidents including near misses can avoid costly accidents. (The
Clapham Junction rail crash and the Herald of Capitalism ferry capsize were both examples of scenarios
where management had cannot recognise, and act upon, previous failings in the system). An
appreciation of how and why things went wrong and an understanding of ways in which people can be
exposed to conditions or substances that may have some adverse ill-effect on their health and safety.
Identifying deficiencies in risk control management, which will enable one to improve the
control/management of risk in the future. By sharing such information, the other parts of the
organisations or similar organisations shall reap benefits, by implementing the lessons learnt in their
safety programs.

Difference between Leading and Lagging Indicators

Lagging indicators measure a company’s incidents in the form of past accident statistics. Examples
include lost workdays, the number of injuries per year, number of specific illnesses and workers
compensation costs. The major drawback to only using lagging indicators of safety performance is that
they tell you how many people got hurt and how badly, but not how well your organisation is doing at
preventing incidents and accidents.

A leading indicator is a measure preceding or indicating a future event used to drive and measure
activities carried out to prevent and control injury. Examples include health & safety training, clear
policies & procedures, safety audits. Leading indicators are focused on future safety performance and
continuous improvement. These measures are proactive in nature and report what employees are doing
on a regular basis to prevent injuries.
 4.2 INVESTIGATING INCIDENTS
Role and Need for Investigation
Incidents and accidents, whether they trigger damage to property or more seriously injury and/or ill-
health to individuals, ought to be appropriately and completely investigated to permit an organization to
take the proper action to prevent its recurrence. Incident investigation is critical in improving an
organisations health and safety performance. Incident investigation is considered to be part of a reactive
monitoring system because it is triggered after an event. The reasons for carrying out accident, incident
and ill-health investigations fall into several categories, each having their own underlying reasons:
 The prevention of future events – prevent a
recurrence and the elimination of cause(s)
 Demonstration of concerns relating to
workers health and safety
 Prevent business losses
 Increase employee morale
 Identify management system weaknesses
 Conformance to Occupational Health and
Safety Management System requirements
 Monitoring and review of company
performance
 Risk Assessment reviews and revisions
 Accident and ill-health data review
 The collation of accident and ill-health
information in a bid to establish trends or compare against ‘bench-marks’
 Defending civil claims for compensation or defending a criminal action

There are immediate and longer terms actions management should take after an accident such as:
 First Aid to injured party
 Calling medical assistance if necessary
 Make area safe
 Isolation of the accident scene
 Implement or initiate emergency plans
 Report to relevant enforcing authority if necessary
 Identification of witnesses
 Setting up investigation team
 Full Investigation to determine root cause
 Making recommendations
 Performing corrective action
Factors to Be Considered Before Undertaking the Investigation
Before the investigation is commissioned, the depth of the investigation and the composition of the
investigation team must be considered, beforehand. Make sure that the accident scene is left
untouched. All related documents must be collated and identify the witnesses and people who could be
interviewed for gathering evidences. Check that all legal reporting requirements have been met. Identify
all the equipment that would be required based on an assessment done. The report style and target
audience must also be defined before the investigation starts.

Investigation Team
Depending on the level and details of the investigation, the team members could vary. For serious
incidents where there are high likelihood of happening again and the consequences could be very
severe, there is need to have a cross-functional team, headed by a
senior manager from a different department to be
involved. The following personnel could be involved in a
detailed incident investigation.
 Line Manager: has knowledge of the processes
involved
 Supervisor: also becomes aware of the process
 Safety Representative: has legal right
 Safety Practitioner: to advice on health and safety
implications
 Engineer: to provide advice on technical matters
 Senior Manager from different department: unbiased

Equipment Needed
Equipment’s must be readily available and accessible during emergencies. Valuable evidence can be lost
if, for example, the camera cannot be found. The following equipment may be required:
 Camera
 Writing materials
 Paper or investigation forms
 Measuring tape
 Area plans
 Personal protective equipment
 Possibly a checklist
The Incident Investigation Procedure
When investigating an accident or other types of incident there are some basic principles and procedures
that can be used:

Step 1: Gathering the information

Gathering and recording information will help to establish the
facts. Evidence is quickly lost at the scene, so it is essential to
preserve the scene and take draw sketches, photographs, and
take measurements prior to any clearing-up that may follow
the accident. Where ill-health is concerned, specific
measurements such as noise levels or radiation levels may be
required. It is important to keep an open mind and not to
dismiss any evidence at this stage. Questions to be asked at
this time can include:
 What activities were being performed at the time?
 Was there anything uncommon or various about the working conditions?
 Were there adequate safe working treatments and were they followed?
 Was the risk known? If so why wasn’t it managed?
 Did the organisation and plan of the work influence the accident?
 Was upkeep and cleaning sufficient?
 Was the safety equipment sufficient?

Factors to be considered:
 Materials
 Equipment
 Environment
 People
 Other Factors
It is important to examine any contradictory evidence carefully and to not dismiss any fact that does not
fit in with the rest. An understanding of the system of work involved is key to the investigation, e.g. is
the nature of the work routine, sporadic or incidental? In particular cases it may be necessary for plant
and equipment, machinery, tools are to be examined by a specialist engineer.
Witness interview techniques
 Not prompting or leading witnesses
 Asking ‘open’ questions (e.g. how, who, what, when, why) such as ‘Can you describe the
function of the machine?’, rather than ‘closed’ questions, such as ‘Is the machine a lathe?’, to
which the person can answer only yes or no
 Not asking long, complicated questions; breaking them up into smaller ones
 Verifying the facts by asking closed questions
 Not making quick judgements about the information.
Review of Documents
Information gathered at the scene may be backed up by documentary evidence such as:
 Risk assessments
 Safe systems of work
 Previous incident and accident records
 Training records
 Maintenance records
 Equipment instructions
 Work place monitoring, e.g. noise, dust levels
 Supervision rotas
 Inspection reports
 Pre-start equipment checks, e.g. guards, fork-lift trucks, etc.

Step 2: Analysing the information

All the gathered facts and data will be examined to determine what happened and why. Analysis should
be systematic, considering the ‘domino theory’, in order to identify:

Immediate/direct causes
The immediate cause of an accident is the unplanned, unforeseen event that has caused the
accident/incident. For example a fork truck may overturn because it is overloaded so the immediate
cause is overloading.
 Unsafe acts and unsafe conditions contribute to immediate causes of accidents.
 Unsafe Conditions: Examples: trailing cables across a walkway creating a trip hazard, incorrect
use of guards.
 Unsafe Acts: Not wearing PPE, horseplay, removing guards. Managers should ensure that
workers receive adequate information, training, instructions and supervision to ensure that
procedures are being followed.
Root causes
The root cause could be considered as the failure of systems and procedures under management’s
control such as no or poor risk assessment procedures, lack of supervision, no defect reporting
procedures etc. There may well be more than one root cause of an accident. For example there could be
a failure in a system but it may also be found that employees have not been trained and there was a lack
of supervision.

Individual and Job Factors (Root and Underlying Causes)

These may be such things as:
 Unclear lines of responsibility or accountability
 Inadequate supervision
 Lack of information, instruction, training or ineffective communication.
These may include factors relating to Materials, Equipment, Environment, People, Organisation and
Management. An essential part of accident investigation is to compare the standard of control with the
standards set out in the risk assessment. Was the risk assessment suitable and sufficient and, if so, why
did the accident occur?
Step 3: Identifying risk control measures
A systematic approach to Step 2 will enable possible solutions to be named. The analysis may have
identified that there were:
 No control measures in place or if so not used
 Control measures in place that failed
 Combinations of the above.
All possible risk control measure should be evaluated for:
 Their ability to prevent recurrences
 Whether they are practical
 Whether they will be used
 Whether they will remain valid.

Step 4: The action plan and its implementation

Senior management should be involved in corrective actions because they have authority to make
decisions and act on recommendations. Consultation with health and safety representatives will be
valuable in deciding what action to take. The highest priority risk control measures should be
implemented first. If the risk is high it will be important to act immediately or put short-term controls in
place. If risks are not high and immediate, control measures can be brought into the action as per the
priority over the short, medium and long-term. A particular senior person, preferably a director, partner
or senior manager, should then be made responsible for ensuring the action plan as a whole is put in
place.

Incident Investigation Report

The contents of a typical incident investigation report may include:
 Date and time of the incident.
 Location of the incident.
 Details of the injured person/persons involved (name, role, and work history).
 Details of injury sustained.
 Description of the activity being carried out at the time.
 Drawings or photographs used to convey information on the scene.
 Immediate and underlying/root causes of the incident.
 Assessment of any breaches of legislation.
 Details of witnesses and witness statements.
 Recommended corrective action, with suggested costs, responsibilities and timescales.
 Estimation of the cost implications for the organisation.
External Reporting
The ILO needs each federal government to nominate a competent authority or authorities, as applicable,
which should, monitor the health and safety conditions of all the businesses/organisations and create,
implement and periodically review a significant national policy and concepts on the recording,
notification and investigation of:
 Occupational accidents and diseases
 Commuting accidents, dangerous occurrences and incidents
 The collecting, analysis and publication of statistics on such accidents, diseases and incidents.

Most of the countries have their own laws, regulations or other methods consistent with local
conditions and practice which require the recording and reporting of events such as occupational
accidents, occupational diseases, commuting accidents, dangerous occurrences and incidents. Not all
accidents are reportable to Enforcing Authorities, but to ensure accurate statistics all incidents and
accidents should be reported internally.

Typical Examples of Reportable Events

There are generally three areas to be reported to government bodies.

Injuries  Death
 Fractures
 Amputations etc.
Diseases  Dermatitis
 Asthma
 Lung diseases etc.
Dangerous Occurrences (High potential near  Collapse of cranes
miss)  Contact with overhead power lines
 Electrical fault causing fire or explosion
 4.3 HEALTH AND SAFETY AUDITING
Meaning of Health and Safety Audit
A health and safety audit can be defined as systematic, independent and documented process for
obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria
are fulfilled.

Scope and Purpose of Auditing Management System

The purpose of audit is to verify the compliance with set standards, efficiency, effectiveness and
reliability
of health and safety management system of an organisation. It ensures an organisation’s safety
management system is being effectively implemented to manage the risk of accidents and ill health
occurring in the workplace. An audit is always carried out on a recognized protocol, or on an existing
safe system of work. If it is already known that the safe system in place is weak or lacking in areas, then
an audit is not the tool to use. Instead a safety survey would be more appropriate as it focuses on the
weak areas of the system until they are resolved. Only when management feels comfortable that a safe
system
is in place, is an audit worthwhile. The audits help in examining and assessing the system and its
implementation to determine if and where the system is failing, if at all.

Distinctions between Audit and Inspections

Audit is an independent, extensive review and evaluation of records and activities to examine the
adequacy of system controls, to make sure compliance with operational procedures and established
policies, and to suggest necessary modifications in procedures, policies, or controls. A safety inspection
involves the simple observation of a work environment and/or the activities or equipment within it. A
safety inspection, usually carried out by a supervisor, employee representative and Safety Advisor and
typically assisted by the use of a list, may be performed routinely. It has the goal of recognizing hazards
& evaluating the usage & effectiveness of control steps.

Types of Audit

Product audit
An examination of a particular product or service (hardware, processed material, software) to evaluate
whether it conforms to requirements
Process audit
A verification that processes are working within established limits - Check the adequacy and
effectiveness of the process controls established by procedures, work instructions, flowcharts, and
training and process specifications

System audit
An audit conducted on a management system.

 A quality management system audit evaluates an existing quality program to determine its
conformance to company policies, contract commitments, and regulatory requirements.
 Similarly, an environmental system audit examines an environmental management system, a food
safety system audit examines a food safety management system, and safety system audits examine
the safety management system.
 A first-party audit is performed within an organization to measure its strengths and weaknesses against
its own procedures or methods and/or against external standards adopted by (voluntary) or imposed on
(mandatory) the organization. A first-party audit is an internal audit conducted by auditors who are
employed by the organization being audited but who have no vested interest in the audit results of the
area being audited.
A second-party audit is an external audit performed on a supplier by a customer or by a contracted
organization on behalf of a customer. A contract is in place, and the goods or services are being, or will
be, delivered. Second-party audits are subject to the rules of contract law, as they are providing
contractual direction from the customer to the supplier.
A third-party audit is performed by an audit organization independent of the customer-supplier
relationship and is free of any conflict of interest. Independence of the audit organization is a key
component of a third-party audit. Third-party audits may result in certification, registration, recognition,
an award, license approval, a citation, a fine, or a penalty issued by the third-party organization or an
interested party.

The Audit Stages

Different audits are run in slightly different ways. What follows is a fairly typical audit process.
Pre-Audit Preparations
Before the audit starts the following should be defined:
 The scope of the audit – will it cover just health and safety, or environmental management as well?
 The area of the audit – one department, one whole site, all sites?
 The extent of the audit – fully comprehensive (which may take weeks), or more selective?
 Who will be required – auditors will need to be accompanied during their visit and will need access
to managers and workers for information-gathering, therefore those required for interviews
should be notified in advance.
 Information-gathering – it is common practice for auditors to ask for copies of relevant
documentation before starting the audit so that they can prepare.

The organisation will have to ensure that the auditor is competent, i.e. that they have the relevant
qualifications, experience and knowledge to do the job well. This can apply to both internal and external
auditors. If internal staffs are used as auditors sufficient time and resources will have to be allocated so
that they can be trained and developed in that role. All of these elements of the audit process require
the allocation of sufficient management time and resources.

During the Audit

Auditors use three methods to gather factual information:
 Reference to paperwork – the documents and records that indicate what should be happening and
what has happened relevant to a particular issue.
 Interviews – word-of-mouth evidence given by managers and workers.
 Direct observation – of the workplace, equipment, activities and behaviour.
Auditors will sometimes seek to collect evidence so that their findings cannot be refuted; this can be
done by copying paperwork, taking photographs and having a witness to corroborate word-of-mouth
evidence. An auditor’s favourite phrases are: “Show me” and “Can you prove it?”
 The Auditors may request documents relative to health and safety to be provided prior to the audit or
for examination during the audit. These documents will include
 Safety policy  Health surveillance records
 Risk assessment procedures  Safety committee minutes etc.
 Safety monitoring procedures  Training records
 Maintenance records  Statutory inspections
 Accident and incident reports  Previous audit reports

At the End of the Audit

Verbal feedback is usually provided at the end of an audit; for some audits this will involve a
presentation to the management team. This verbal feedback will be followed by a written report. The
report will make recommendations for improvement and indicate priorities and timescales.

Responsibilities for Audits

Management is responsible to ensure that safety audits are conducted regularly and that everyone will
participate in the process. The audit team may be just one person or a group of individuals. The number
of auditors involved depends upon the size of the organisation and the audit objectives. Auditors need
to be competent and this includes having technical ability, knowledge and experience of auditing,
interpersonal, report writing and presentation skills. They may be external and internal auditors

Advantages and Disadvantages of External and Internal Audits

Internal Audit’s Advantages Internal Audit’s Disadvantages

 A lower cost than external audit and  The internal team may be under pressure
easier to arrange from management to get the audit
 Recommendations and actions are more completed quickly
likely to be accepted and implemented  They may not have any auditing
 Internal team is already familiar with the experience or training
organisation and its strengths and  Their work load may be increased by the
weaknesses additional responsibilities of the audit,
 They will have knowledge of the which may affect judgments
company’s existing precautions and  They may not be up to date with current
hazards legislation
 Employees may not feel threatened  Employees could be influenced by internal
during interviews relationships and pressures

External Audit’s Advantages External Audit’s Disadvantages

 Will be independent and not be biased  The auditors may produce unrealistic
and will see performance as it is targets
 Can be costly
  Auditors will be impartial and will have  A lot of planning is required to familiarise
much experience in different work themselves with the company
practices  It may be difficult for the external team
 The external auditors will not be inhibited to get information from employees.
by criticism Employees may feel more threatened
 The audits may be able to find solutions
to problems that the organisation has not
been able to solve

Audit Action Plan

Once the findings have been formulated it is necessary to prioritise them so that the management will
know which ones to address first and which last.
 First priority - High inherent risk and a weak system in place, e.g. fire detection equipment is
broken and no system is in place to replace it.
 Second priority - High inherent risk and a robust system in place, e.g. fire detection equipment
is broken but there is a system in place to pick this up. Work on the equipment has been
approved but has not yet been completed.
 Third priority - Low inherent risk and a weak system in place, e.g. extract ventilation on
degreasing bath is not entirely functional and there is
no testing schedule.
 Fourth priority - Low inherent risk and a robust
system in place, e.g. extract ventilation on degreasing
bath not fully functional but a testing schedule is in
place to check the equipment next month.

The Organisation should take action to feed the information

back into management system and to implement any action
required. Action plans may be draw up to ensure that the
implementation of measures required will be completed to a suitable time scale and that all relevant
members of the workforce are aware of what is needed of them.
 4.4 REVIEW OF HEALTH AND SAFETY PERFORMANCE
Purpose of Reviewing Health and Safety Performance
Measuring and reviewing performance is an essential step in the management of health and safety. It
shows how the OSH management system functions and recognizes any weak points that need
improvement, and how well you are going to achieving your mentioned health and wellness goals and
goals. Evaluating the health and safety performance enables Organisations to:
 Degree of compliance against identified performance standards
 Confirming if health and safety policy is relevant and valid.
 Check adequacy of the arrangements for managing the health and
safety
 Identifies strengths, weaknesses and areas for improvement.
 Checking if objectives and targets are achieved
 Identify the efficient use of resources and the need to allocate more
 Managing changes in the organisation effectively, by assessing its impact
on health and safety and allow management to make appropriate
provisions to deal with the changes.
Review Team
The involvement of top management is critical at the planning and review stage of management system,
as the key decisions are made at these two stages. Managers, supervisors, health and safety advisors,
employee representatives and even someone independent, perhaps from another business area, could
add value to the process. All participating individuals must be trained and be competent to make
informed judgements about monitoring performance. Employees should also be encouraged to inspect
their own workplace frequently and to report any safety problems to their supervisors. It must be
emphasised that all levels of management have a role to play in the review process.

Scheduling Reviews
Review schedule/frequency will depend upon the risk profile of the organisation as well as statutory
requirement. As a general guide, senior management should examine the premises at annual audits.
Supervisors may conduct weekly inspections of activities to identify any unsafe conditions and unsafe
acts. Health and Safety advisors and employee representatives may carry out weekly inspections, or
more frequently depending on risks and activities, in particular with non-routine activities. More
frequent monitoring is necessary if the activities are high risks with serious consequences.
Managing Change and Continual Improvement
Reviewing provides opportunities for management to check if the health and safety environment in the
business has changed. This enables management to stop doing things that are no longer necessary while
allowing them to respond to new risks. It is widely recognised that engineered changes, if not properly
considered and controlled, can have potentially significant safety implications. Many of the potential
adverse effects on safety of organisational change can be avoided if consideration is given to the effects
of changes before they take place. In recent years, the obvious needs to reduce costs and improve
 efficiency have led many companies (including smaller organisations) to consider how they might
improve work processes and change organisational structures.

Factors to Consider for Review

Reviewing health and safety performance relies to a great extent on having good-quality, reliable
information about current and past performance, which usually depends on data gathering. One of the
first steps in the review process is gathering this information and data. There is a wide range of topics
for consideration in the review including:

Legal compliance – the organisation must be aware of any legal compliance issues, and therefore the
review should include a report (possibly from the safety advisor) on any outstanding issues. An
organisation may also have specific internal requirements, e.g. higher standards imposed from a parent
organisation, which should also be considered in this section.
Accident and incident data – clearly, the number and type of injury accidents, property damage
accidents, lost-time accidents, reportable events, etc. should be reviewed as a reactive measure of
health and safety performance, together with the review of actions arising from the investigations, to
ensure that these are closed out.
Findings of safety surveys, tours and sampling and workplace or statutory inspections – may
provide evidence of conformance or non-conformance to standards.
Absence and sickness data – information concerning work-related ill health, from absence monitoring
records, or perhaps the occupational health department (if one exists) should be reviewed in order to
determine if there are patterns of absence.
Audit reports – findings of internal and external audits should be reviewed, which may present
detailed and comprehensive information on the safety management system and its effectiveness.
Monitoring data/records/reports – the findings of monitoring activities should be considered. For
example, if a noise-exposure monitoring activity was carried out a summary of the findings should be
reviewed.
External communications and complaints – there are various potential external sources of
communication, from regulators to people who live near your premises. If complaints or issues are
raised these should be considered so that action can be taken, as required.
Consultation – the organisation should be consulting with the workforce on health and safety matters,
so a summary of issues raised could be considered. It may be appropriate to highlight major issues
rather than the minor details, which should have been addressed at the consultation stage.
Objectives met – the review should consider the organisation’s progress against stated health and
safety objectives. If the plan states that: “Manual handling training will be rolled out to all employees by
the end of July”, monitoring progress of this objective in the regular reviews will keep it on track. The
annual review should consider which of the objectives were achieved in the year.
Actions from previous reviews – actions will arise at each review, and progress must be monitored to
ensure they are closed out.
Legal and best-practice developments – there may be new legal developments that will impact the
organisation in the future, and advance warning of this will enable the organisation to develop a plan to
achieve compliance in time to meet legal deadlines.
Maintenance of Records of Management Review
Following the review, a detailed written report should be produced and the results presented to the
Board and the organisations senior management. The report should consist of a summary of the
findings, highlighting the most significant problems, detailing the compliances with and the failures of
the safety management systems, and recommendations for enhancement.

Reporting On Health and Safety Performance

Organisations must have a mechanism and established system to report on safety performance and to
ensure that legal compliance is achieved and maintained. There should also be a process to report
serious incidents immediately. This will allow management take action to tackle poor performance as
well as establishing key performance indicators to help meet health and safety objectives.

Feeding Into Action and Development Plans as Part of Continuous

Improvement
The organisation should then take action to feed the information back into the management system and
to implement the action required. Action plans shall be prepared to ensure that the implementation of
measures required will be completed in a suitable time scale and that all relevant members of the
workforce are aware of what is needed of them.
Summary
This element has considered the measuring, audit and review aspect of health and
safety management systems. In particular, it has:
 Differentiated between active monitoring (checking to ensure that standards
are met before any untoward event takes place) and reactive monitoring
(measuring safety performance by reference to accidents, incidents and ill-
health that have already occurred).
 Outlined some active monitoring methods (inspections, sampling, surveys
and tours) and explained the factors that must be considered when setting
up an inspection system.
 Considered how to write an effective inspection report.
 Considered the reasons for accident investigation, perhaps the most
important of which is to discover the causes so that corrective action can be
taken to prevent similar incidents from happening again.
 Described a basic investigation procedure.
 Outlined the arrangements that should be made for the internal reporting of
all work-related incidents and the records of work-related injuries that
should be kept.
 Defined the types of incident that have to be reported to external agencies,
such as fatalities, major injuries, occupational diseases and dangerous
occurrences.
 Defined auditing as the systematic, objective, critical evaluation of an organisation’s
health and
safety management system.
 Outlined the steps of an audit process, considered the types of information
that might be used as evidence, and identified the strengths and weaknesses
of external and internal auditing.
 Outlined the part that health and safety performance review has to play in
ensuring continuous improvement.
 Identified the information sources that might be used in reviewing performance and
the role that