EPAZ Presentation lessons from ehs audits... · HEALTH and SAFETY, LLC. In this presentation, we...

HEALTH and SAFETY, LLC

EPAZ Presentation

by Richard (Rick) Haskins, M.P.H.C.P.E.A. (E), C.P.E.A. (H&S), C.P.S.A.

Managing PartnerHealth and Safety, LLC

March 16, 2017


Lessons from EHS AuditsPerspectives from Both Sides

&

The Greater Purpose

Presenter

Presentation Notes

These lessons apply to assessments, surveys, inspections, walk-throughs, walk downs, etc.


In this presentation, we will discuss the following:

The reasons EHS Audits are necessary and performed

Insights on how to successfully perform prior to, during, and after an EHS Audit

Perspectives from both sides of an EHS Audit; as an auditee and as an auditor

Things to Do (or Not Do) and Say (or Not Say) during an EHS Audit

Good Examples and Poor Examples of Compliance

Objectives


Reasons Audits Are Performed

The reasons audits are necessary and performed are:

Provide a timely benchmark for management

Identify areas of non-compliance that may need resources to resolve

Identify opportunities for improvement

Share Best Management Practices from other facilities

“What gets measured, gets done!” – W. Edwards Deming & Peter Drucker

If one does not keep track of how well they are doing, how does oneknow if they are getting better or not?


Tips For Success Prior To EHS Audits

The three most important things of an EHS Program:

Organization, Organization, Organization

Organized Program

Organized Site

Organized Recordkeeping



Organized Program

Air, Water, Waste, Health, and Safety

Trained Personnel – Management, Professional, & Frontline

Assignments and Accountability

Good, Open Communication

Frequent Oversight

“If you can't describe what you are doing as a process, youdon‘t know what you're doing.” – W. Edwards Deming



Organized Site

“A place for everything and everything in its place”

Designated Areas and Places (i.e., Satellite Accumulation Areas, Portable Fire Extinguishers, etc.)

Good housekeeping and cleanliness



Organized Recordkeeping

A file for everything & everything in its file

Ease of retrieval of electronic files and/or hard files

Appropriate documentation (check sheets, reports, etc.)

Frequent review of documentation


Tips For Success During EHS Audits Provide the requested records and documents ASAP

Accompany the auditors during the site walk down

Be professional

Treat the other person the way you would expect to be treated, if the roles were reversed

Correct what you can as quickly as you can – “Fix It Now”


Tips For Success After An EHS Audit

Correct what you can as quickly as you can

Prioritize Corrective Actions

Prepare a Corrective Action Plan

Provide frequent updates (at least quarterly) to the Auditors and Management on the completion of the Corrective Action Plan


Things To Do and Say As an Auditee:

Accompany the auditors during the site walk down

Take pictures of the audit findings (these can be used for documenting corrective actions and training)

Respectfully challenge audit findings you do not agree with – “May we discuss this finding further?”

Be present, engaged, and professional

Be forthright and forthcoming


Things To Do and Say As an Auditor:

Inform the facility when you know you have a finding; right then

Take pictures of your audit findings

Be able to defend your audit finding with objective information

Be respectfully firm in your findings but agree to discuss further

Be willing to admit that you were wrong and change your mind

Be an active listener

Be “Firm, Fair, and Friendly” – Sherry Haskins


Things Not To Do and Say As an Auditee:

Be negative

Be argumentative

Disrespectfully challenge audit findings you do not agree with – “That is the dumbest regulation I ever heard of!” or “You are one picky son-of a gun!”

Be deceiving or dishonest

Be uncooperative


Things Not To Do and Say As an Auditor:

“This is the worst situation I have ever seen!”

“This is the best program I have ever seen!”

“What in the hell?” or “Gold Mine!”

Be argumentative with your findings and not agree to discuss further

Surprise the facility with audit findings on the last day

Not be able to successfully defend your audit finding(s)


Examples of Poor and Good Compliance Air Water AST’s TSCA Used Oil Hazardous Waste Universal Waste Medical Waste FIFRA EPCRA Electrical Fall Protection


Examples of Poor and Good Compliance Note how often poor organization and poor housekeeping goes hand-in-

hand with poor compliance

Note how often good organization and good housekeeping goes hand-in-hand with good compliance


Poor Example of ComplianceInadequate Dust Control Measures

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Presentation Notes

Water Violation


Good Example of ComplianceAdequate Dust Control Measures

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Presentation Notes

Water Violation


Poor Example of ComplianceInadequate Air Gap and Potential Cross Connection

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Presentation Notes

Water Violation


Good Example of ComplianceAdequate Air Gap

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Presentation Notes

Water Violation


Poor Example of ComplianceAboveground Storage Tank – No Secondary Containment


Good Example of ComplianceAboveground Storage Tank – Secondary Containment


Poor Example of ComplianceUnlabeled Transformer

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Presentation Notes

TSCA Violation


Good Example of ComplianceNon-PCB Labeled Transformer

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Presentation Notes

TSCA Violation


Poor Example of ComplianceImproper Used Oil Labeling and Storage


Good Example of ComplianceProper Used Oil Labeling and Storage


Poor Example of ComplianceHousekeeping & Organization


Good Example of ComplianceHousekeeping & Organization


Poor Example of ComplianceUnlabeled Drums with Unknown Contents


Good Example of ComplianceLabeled Drums with Known Contents


Poor Example of ComplianceInadequate Aisle Space & Unlabeled Drums


Good Example of ComplianceAdequate Aisle Space & Labeled Drums


Poor Example of ComplianceSatellite Container – Not Closed & Not Properly Labeled


Good Example of ComplianceSatellite Container – Closed & Properly Labeled


Poor Example of ComplianceImproper Storage – Not Closed & Not Properly Labeled


Good Example of ComplianceProper Storage – Closed & Labeled


Poor Example of ComplianceImproper Storage of FIFRA Products

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Presentation Notes

FIFRA Violation


Good Example of ComplianceProper Storage of FIFRA Containers

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Presentation Notes

EPCRA Violation


Poor Example of ComplianceEPCRA Violation – No Safety Data Sheets & No Inventory

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Presentation Notes

EPCRA Violation


Good Example of ComplianceEPCRA – Safety Data Sheets & Inventory

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Presentation Notes

Flammable Storage Cabinets should be neatly organized and contain flammable products. All chemicals should be stored in their original containers and labeled clearly.


Poor Example of ComplianceMedical Waste – No Durable Container


Poor Example of ComplianceMedical Waste Container – Labeled, Impervious, Durable


Poor Example of ComplianceKnockout Missing – Exposed Electrical Hazard


Good Example of ComplianceNo Knockout Missing – No Exposed Electrical Hazard


Poor Example of ComplianceOpen Blanks on Overcurrent Protection Device


Good Example of ComplianceNo Open Blanks on Overcurrent Protection Device

Presenter

Presentation Notes

Each service, feeder, and branch circuit, at its disconnecting means or over current device, shall be legibly marked to indicate its purpose


Poor Example of ComplianceImproper Use of Electrical Equipment

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Presentation Notes

Quad box designed for permanent installation, not as an outlet for flexible extension cord


Good Example of ComplianceProper Use of Electrical Extension Cord

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Presentation Notes

Flexible cords shall be used only in continuous lengths without splice or taps


Poor Example of ComplianceCover Missing – Exposed Electrical Parts


Good Example of ComplianceElectrical Cover Provided – No Exposed Electrical Parts


Poor Example of ComplianceDaisy Chaining of Power Strips


Good Example of ComplianceProper Use of Power Strips


Poor Example of ComplianceFall Protection Not Provided


Good Example of ComplianceFall Protection Provided


Poor Example of ComplianceNo Guardrails in Place


Good Example of ComplianceGuardrails In Place & Properly Constructed


Poor Example of ComplianceImproper Guarding of Protruding, Reinforcing Steel

http://www.osha.gov/SLTC/etools/construction/images/rebarincident1.jpg

http://www.osha.gov/SLTC/etools/construction/images/rebarincident1.jpg


Good Example of ComplianceProper Guarding of Protruding, Reinforcing Steel


Poor Example of ComplianceHousekeeping and Limited Access Zone


Good Example of ComplianceHousekeeping


Summary – Don’t Forget the Greater PurposeIn this presentation, we discussed the following:

The reasons EHS Audits are necessary and performed

Insights on how to successfully perform prior to, during, & after an EHS Audit

Perspectives from both sides of an EHS Audit; as an auditee and as an auditor

Things to Do (or Not Do) and Say (or Not Say) during an EHS Audit

Good Examples and Poor Examples of Compliance


Questions or Comments

Questions?


Thank You

Richard (Rick) Haskins, M.P.H.C.P.E.A. (E), C.P.E.A. (H&S), C.P.S.A.

Managing PartnerHealth and Safety, LLC

[email protected](480) 229-7757

mailto:[email protected]

Short Bio – Richard (Rick) Haskins

Bachelor of Science (B.S.) Arizona State University Tempe, Arizona Double Major: Health Science & Health Education Master of Public Health (M.P.H.) University of Michigan Ann Arbor, Michigan Double Major: Environmental Health & Public Health Administration Certified Professional Environmental Auditor (C.P.E.A.) – Environmental Certified Professional Environmental Auditor (C.P.E.A.) – Health & Safety Certified Process Safety Auditor (C.P.S.A.) Managing Partner of Health and Safety, LLC. This company provides Environmental, Health, Safety, and DOT Assessments, Audits, Consultations, and Management. Retired EHS Audit Consultant - APS Over 18 years of experience as the Lead Environmental, Health, Safety (EHS)and DOT Auditor for Arizona Public Service Company (APS), a regional electric utility company. Duties included identifying and assessing applicable legal and regulatory requirements of environmental, health, safety, and DOT programs in nuclear, coal-fired, gas, and hydro power plants, service centers, laboratories, and business offices. Retired Commissioned Officer (O-6) - U.S. Public Health Service Over 22 years of service as a Commissioned Officer in the U.S. Public Health Service. Duties included planning, organizing, developing, implementing, directing, coordinating, supervising, and evaluating an Area-wide environmental health, safety management, occupational health, industrial hygiene, infection control, and risk management program in 3 medical centers, 3 hospitals, 7 health centers, and 21 health clinics.

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