epaz presentation lessons from ehs audits... · health and safety, llc. in this presentation, we...
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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
HEALTH and SAFETY, LLC
Lessons from EHS AuditsPerspectives from Both Sides
&
The Greater Purpose
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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
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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?
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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
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Tips For Success Prior To EHS Audits
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
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Tips For Success Prior To EHS Audits
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
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Tips For Success Prior To EHS Audits
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
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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”
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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
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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
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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
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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
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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)
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Examples of Poor and Good Compliance Air Water AST’s TSCA Used Oil Hazardous Waste Universal Waste Medical Waste FIFRA EPCRA Electrical Fall Protection
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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
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Poor Example of ComplianceInadequate Dust Control Measures
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Good Example of ComplianceAdequate Dust Control Measures
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Poor Example of ComplianceInadequate Air Gap and Potential Cross Connection
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Good Example of ComplianceAdequate Air Gap
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Poor Example of ComplianceAboveground Storage Tank – No Secondary Containment
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Poor Example of ComplianceUnlabeled Transformer
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Good Example of ComplianceNon-PCB Labeled Transformer
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Poor Example of ComplianceSatellite Container – Not Closed & Not Properly Labeled
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Poor Example of ComplianceImproper Storage – Not Closed & Not Properly Labeled
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Poor Example of ComplianceImproper Storage of FIFRA Products
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Good Example of ComplianceProper Storage of FIFRA Containers
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Poor Example of ComplianceEPCRA Violation – No Safety Data Sheets & No Inventory
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Good Example of ComplianceEPCRA – Safety Data Sheets & Inventory
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Poor Example of ComplianceMedical Waste Container – Labeled, Impervious, Durable
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Good Example of ComplianceNo Open Blanks on Overcurrent Protection Device
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Poor Example of ComplianceImproper Use of Electrical Equipment
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Good Example of ComplianceProper Use of Electrical Extension Cord
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Good Example of ComplianceElectrical Cover Provided – No Exposed Electrical Parts
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Poor Example of ComplianceImproper Guarding of Protruding, Reinforcing Steel
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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
HEALTH and SAFETY, LLC
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
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.