Internal audits are a fact of life for many environment, health and safety professionals -- especially those working for large companies. I recently had a discussion with a long-time Phylmar client about internal safety audits. There is a lot of guidance and advice available on how to prepare for such audits and how to create corrective action plans to respond to audit findings. What I found most interesting in the discussion with our client, however, was the cost of managing findings. As a result, I’d like to offer some thoughts on why and how to reduce the sheer number of audit findings while the audit is underway.
Internal Audit Findings: Why The Numbers Matter
Does this scenario sound familiar to you? An internal auditor includes a “finding” in his/her audit report that’s classified as “minor” or a “suggestion for improvement.” You, as auditee, are required to address this finding or suggestion in your Corrective Action Plan. Perhaps the suggestion or finding would improve or streamline a safety management system, from the auditor’s perspective, and you think it might not take a lot of work to accomplish it, so you go ahead and add it to your list of items for which you must identify corrective or preventive actions. Or maybe you even think the auditor’s actually got their information wrong, but it’s already in the report and it wouldn’t really be a big deal to respond in your Corrective Action Plan. Right? Well, maybe not.
“Bad” or unnecessary findings cost you. Think about it. These must be input into your CAPA tracking log, which is not as simple as it sounds. One or more individuals need to craft the corrective or preventive action. They need to identify one or more responsible individuals to execute it and document it. Eventually, the internal audit team will need to verify that the finding or suggestion has been closed out or resolved.
A lot can happen in the mean time --for instance, process, equipment, and/or personnel changes. Tweaking a system that managers and employees are already engaged with costs you in terms of training time. If those tweaks are not truly necessary, that is wasted time. You may find yourself having to convince management of the need to make changes to systems or operations that may not make sense to any of you. And lead auditors and audit teams change, as well. You could find yourself trying to explain to a new lead auditor why a finding never should have been made in the first place. Finally, while this is all going on, someone (or some system) must be tracking the corrective or preventive action and making sure it’s progressing on time.
The bottom line here is that all audit findings and even the “suggestions for improvement” (if they must be addressed by you and your team) take time and resources to address, even if it’s only inputting them into your system, making “minor” changes and then tracking them to completion. It’s in your best interest and that of your colleagues to do what you can to avoid any unnecessary audit findings.
Minimizing the Number of Unnecessary or Extraneous Audit Findings
What are some ways that you can minimize the sheer number of audit findings or suggestions that end up in audit report you receive?
First, it’s important that you, as audit host, or auditee, participate fully in the internal audit from the very beginning. Establish a good channel of communication with the lead auditor so that you understand the audit scope and audit schedule. Understand who is included in the audit team and know what their backgrounds are. If possible, reach out to colleagues at other company locations and learn about their experiences with the audit team.
Understand the audit logistics -- who will accompany the internal audit team? Will you attend or receive daily de-briefings? What opportunities will you have to listen to the auditor’s observations and findings? How much time will you have to provide more documentation or evidence where you disagree with observations or findings? Your goal should be to collaborate with internal auditors for the good of your site or organization. This may not include accepting every suggestion or minor finding you are given. As we described earlier, that can cost you time and resources, as well.
Speak Up On the Spot or at Daily Debriefings. Once the audit is underway, participate actively in the daily debriefings or even on the spot, if you accompany the internal audit team. Of course, you don’t want to come across as defensive or argumentative, but if you’re not certain about an observation or finding, question it. Get the details you need to understand the rationale for it. Make sure you understand what requirement or standard has not been met. (1) If you don’t understand the rationale or disagree with it, ask more questions. Speak up: it’s much better (and easier!) to avoid or reduce the scope or severity of a finding at this point in the process.
Get What You Need to Understand the Rationale. If you are not convinced about a finding and did not accompany the audit team in the field, ask to see photos or to visit the finding location with the auditor. If the finding cannot be completely avoided, see if it can be modified so that it seems reasonable to you. Ideally, you’d like to agree that it is something that you (and your management) can and should address. At the very least, you want to be able to understand the auditor’s perspective, even if you disagree with it. Management, supervisors and others will be more sympathetic to a clear rationale for a finding and the need for action to resolve it than with an “I don’t know why” or “this is a senseless finding, but we have to do it” rationale.
Try to Avoid Double-Dipping. Finally, do your best make sure that the audit team doesn’t “double-dip.” While finding “evidence” may apply to two or more audit criteria, it’s not efficient for you to receive multiple findings if one fix will work. So… if two or more findings would actually all be resolved with the same corrective action, request that the auditors consolidate them into one. This will greatly simplify the corrective action process and reduce the time involved in tracking multiple actions to closure. (2)
- Connor, Tony, “Adding Value to an Internal Audit System,” June 6, 2016. Online. International Food Safety & Quality Network website. http://www.ifsqn.com/articles.html/_/articles/adding-value-to-an-internal-audit-system-r54
Clark, Cameron, “Safety Audits: 10 Ways to Get the Most Out of Them,” November 10, 2017. Online. ISO 45001. http://www.theauditoronline.com/safety-audits-10-ways-to-get-the-most-out-of-them/