Pressure to increase productivity, tighter profit margins, cuts in work forces and safety staff. It seems like a very good time to audit whether your current operations are compliant with all relevant health and safety laws. I have developed a comprehensive auditing tool that I’m willing to share with any organizations that are genuinely interested in conducting such an audit.

The Compliance Audit Challenge

Auditing your current compliance levels is critical to planning, budgeting and continuous improvement. But the commitment to audit is one you shouldn’t undertake lightly. Once you perform an audit, you’re on record for any deficiencies you find. This is fine as long as you take steps to correct those problems. But if you neglect them, the audit becomes evidence of a lack of commitment and could lead to liability.

Establishing the basic compliance audit program is a key first step in the process. Other steps include deciding what to audit, when to audit, what audit tool to use, who will conduct the audit, what form of training in the audit process will the auditor(s)  be given, how it will be handled and who will oversee the program.

The auditing toolkit will help you address many of these questions, especially with regard to which auditing tools to use.

The Compliance Audit Toolkit and How to Use It

The compliance audit toolkit I’ve created consists of 4 components:

1. A Model Protocol for conducting the audit;
2. A Model Audit Questionnaire;
3. A Model List of Recommended Actions (deliberately left blank); and
4. A Model Proposed Corrective Action document.

You can use the links above to get access to each component.

Before You Use the Compliance Audit Toolkit

You need to do a little work to adjust the tool before you use it. First, understand that the tool is designed for a specific kind of operation: truck driving. Accordingly, it incorporates elements from OSHA, environmental and Department of Transportation laws that pertain to truck drivers. You’ll need to make modifications to ensure that the audit addresses regulatory requirements pertinent to your industry.

One more caveat: I created the tool a few years ago. So you’ll need to update it to reflect any new or changed OSHA, EPA and DOT requirements. And, of course, if you’re from Canada, you need to adapt it so it addresses Canadian requirements.

Bottom Line: Rather than trying to use it right out of the box, treat the toolkit as a framework for building an audit program that meets the needs of your particular industry and regulatory environment. Having the toolkit as a framework should save you a lot of time and energy.

Conclusion

One final piece of advice: Talk to a lawyer before you initiate your program. In addition to helping you make sound decisions, the lawyer can take steps to protect you such as setting you up to use the Attorney-Client privilege to avoid having to disclose the deficiencies you find to OSHA officials and prosecutors. Getting the lawyer involved may ensure that your internal audit results don’t become Exhibit A in your own prosecution.

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