“There are no secrets to success. It is the result of preparation, hard work, and learning from failure.” Colin Powell
Before I began working in process safety, I worked in banking. As with the process industry, we had rules and regulations, and repercussions if we failed to comply with them. As a manager, it was my responsibility to ensure that I and the employees reporting to me were in compliance and meeting expectations. Any time we were greeted in the morning by well-dressed individuals carrying clipboards and briefcases, I inwardly cringed.
Audits and inspections aren’t fun, but they are necessary, especially when it comes to workplace safety. We’ve all heard of OSHA inspections, but OSHA encourages self-audits as well. When it comes to the Process Safety Management Standard (PSM), OSHA goes beyond encouraging audits—OSHA requires PSM Compliance Audits of PSM-covered processes every three years under the PSM standard. Understanding the difference between audits and inspections can better prepare you when you are facing your own.
What’s the Difference?
While audits and inspections sound like the same thing, there are noteworthy differences between the two. For instance, imagine taking your car in for routine maintenance and your mechanic suggests that you should replace your windshield wipers soon because they aren’t performing as they should. You can choose to heed his warning and replace the wipers, or you can ignore the suggestion and continue to drive your car as is. Now, imagine instead that the same car is due for inspection as part of renewing its vehicle registration. You haven’t replaced the windshield wipers and, as a result, the mechanic at the inspection station tells you he can’t pass the car.
In Missouri, we can’t renew our plates until the problem is corrected and the car passes inspection. If we don’t get the problem corrected soon enough, we face the possibility of driving on expired tags, which have their own penalties. That is the difference between audits and inspections. In either case, we may discover problems that we need to address, but an inspection carries penalties in addition to fixing the problems that need fixing anyway. In the car analogy, the routine maintenance is the equivalent of an audit; the inspection speaks for itself.
What’s the Goal?
Audits and inspections share an end goal. They evaluate compliance to ensure safety. The difference is in the approach each method utilizes to achieve the goal. Audits identify gaps and provide an opportunity to correct them before they are subject to additional legal or monetary consequences. The purpose of an audit is not to penalize, but to inform. Inspections, on the other hand, penalize the gaps. Whether the gaps are willful or simply hadn’t been identified yet, inspectors demand that gaps be addressed and also issue penalties. Even an “internal audit” is really an inspection when an organization uses the findings to punish personnel.
Audits assist in compliance while inspections assess it. Trying to talk an inspector out of a finding might save on fines or other penalties; trying to talk an auditor out of a finding is nonsensical since their findings are only beneficial to the organization.
Who Leads the Effort?
Inspections are conducted by someone in power, someone representing an independent organization with the means to issue citations, fines, or penalties. Inspection should follow due process and provide a chance to rebut findings.
Audits are less formal. In fact, there is no specific requirement, even in OSHA’s PSM standard, that they be conducted by a third party. OSHA’s requirement for PSM Compliance Audits is that at least one member of the audit team is knowledgeable about the process that is being audited. So, while inspections typically come as a surprise, audits can be planned to fit the needs and schedule of the organization being audited.
What’s at Stake?
The ramifications of the findings from an inspection can be substantial. Depending on the party conducting the inspection, penalties can include probationary periods, demotions, fines, or even legal action. The ramifications of the findings from an audit, on the other hand, is that the gap must be closed, something that should happen in any case.
It may be tempting to defer addressing the findings of an audit, since there are no associated penalties. Do not give into that temptation. When an OSHA inspection discovers a gap in compliance was uncovered during an audit, but efforts haven’t been made to correct the gap, the employer is then subject to citation for a willful violation. The penalties for a willful violation are ten times higher than for other violations.
Audits are most beneficial when they are viewed as a tool instead of an imposition.
Inconvenience or Opportunity?
Prompted or not, inspections happen. They usually happen without any warning or time to prepare, leaving an organization vulnerable. When audits are completed in a thorough manner and on a timely basis, they offer an opportunity to correct any gaps or lapses before an inspector shows up to issues citations and fines. The resources expended to complete an audit and resolve the findings are much less than those for an inspection.
Audits are almost always inconvenient and dedicating the resources to their completion generally isn’t at the top of anyone’s wish list. As Confucius said, “An inconvenience is an unrecognized opportunity.” If we can learn to recognize the opportunity in the inconvenience, audits can be used as tools, not only to ensure compliance and minimize citations and fines, but, more importantly, to ensure the safety of the individuals working within the process or organization.