Auditing for Enhanced Performance DHHS 3rd Annual Environmental Networking Workshop May 5, 2004 Rand

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Auditing for Enhanced Performance DHHS 3rd
Annual Environmental Networking Workshop May 5,
2004Randle K. Bunner
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Overview

• Auditing Construct
• Auditing Goals
• Auditing Process
• Good Audits

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Construct Traditional (ISO 9000like) approach
to EMS auditing and certification

Does documented system conform?
Do practices conform to documented procedures?

• Focuses on conformance (to the standard)
• Centered around the documented system manual
• Not consistent with the way people (managers) get
  results

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Construct Managers use a variety of techniques
to produce outcomes

• Use of documented procedures typically represent
  less than 10 of the body of techniques used by
  managers to drive performance
• Environmental, health, and safety outcomes are a
  product of management and operator behaviors

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Construct All environmental outcomes are a
product of management and operator behaviors
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Auditing management and operator behaviors and
outcomes to drive improvement

• Goal should NOT be to
• Soothe management and relieve them of
  responsibility
• Beat up on management, EHS personnel, and
  operators

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Auditing management and operator behaviors and
outcomes to drive improvement

• Goals should be to
• Establish how it is
• Help the organization you are auditing,
  especially management, see how it is frankly
  (especially where it is seriously wrong)
• Determine why things found to be NOT OK could be
  serious
• Make management feel accountable for fixing it

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Process for auditing management and operator
behaviors and outcomes to drive improvement

• Communication before the assessment
• Opening meeting
• Site tour
• Root cause analysis
• Business performance review
• Environmental management review
• Meeting with top person
• Closing meeting

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Communication prior to the audit

• Obtain performance data via questionnaire
• Ensure audit approach AND style understood
• Encourage active and positive engagement
• Agree schedule especially timing of opening and
  closing meeting and meetings with senior
  personnel
• Understand the issues and plan to make the most
  of the time available.
• Discuss logistics
• Cameras
• Meeting facilities
• Protection equipment
• Start/finish times

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Opening Meeting

• Review of approach AND style
• Focus on operation, people, processes (real
  ones), and practice
• Open sometimes repetitive - questioning to
  reveal how it is
• Set the scene for the closing meeting
• Can management be comfortable with the way they
  are looking after EHS aspects of the operations
• Agree logistics
• Confirm scope

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Site tour

• Seeking to center the audit on performance
  outcomes by focusing on
• Potential accidents and incidents
• Non-compliance
• Ongoing impacts
• Good Processes Good Outcomes
• Poor outcomes process weaknesses
• Testing deliverables by seeking examples of poor
  outcomes a weak audit will have failed to find
  deficiencies which are present

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Site tour

• Focus on key discharges, ultimate discharge
  points, chemical handling and storage, lifting
  gear, drainage, roof work, fire control,
  contractor activities
• Start outside and work in
• Escorts should photograph every issue you see
• Include sources, pathways, receptors and
  consequences for them
• Use to provide focus
• Use for training, closing meeting
• Helps eliminate argument and focuses action on
  the ground

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Identifying weaknesses in management of the
environment
Observed poor practices
Weaknesses in management of the environment on
site
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Root cause analysis

• Everything you see is material evidence of
• Operator behaviors
• Extent of management engagement in driving
  environment
• Effectiveness of programs established by
  management
• For the selected issue or fact, seek to
  understand through discussion with escorts,
  operators, supervisors, and managers
• Operator behaviors which have given rise to the
  observed outcome/fact
• Why operators have failed to do what the should
  have or why they have done the wrong thing
• The cause of this is .

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Root cause analysis

• Never make assumptions - seek only explanations
  for what you have discovered
• Questioning style should be open, indirect, never
  leading
• Keep escorts with you and solicit their input
• Auditing exercises should take 3 to 4 hours (or
  more), so carefully select the issue for analysis
• Agreed problem and of some concern
• Crosses boundaries (shifts, departments, relevant
  to many)

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Rules of root cause analysis

• Ensure people are relaxed use small talk and
  humor
• Dont ask leading questions
• Avoid confrontation
• Avoid mentioning the issue
• Make people feel comfortable
• Analysis can lead in different directions
  examine issues vertically and horizontally
• Goal is to really understand how it works in
  practice and where the process failed to give
  rise to the issue

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Rules of root cause analysis

• Ground rule - ask escorts not to interfere with
  questioning
• Make sure escorts are listening
• Really listen and learn
• Listen to what people are not saying
• Watch body language

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Questioning Guide

• Human failing correct way established by
  someone, but for some reason hasnt been followed
• Individual(s) used to know the correct way, but
  had forgotten
• Individual(s) knew the correct way, but didnt
  follow in this occasion
• Individual(s) knew the correct way, but routinely
  didnt follow it
• Individuals didnt know the correct way and never
  did

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Weaknesses in management of the environment
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What are the potential issues here?
James Dean
Matt Dowson
5/6/98
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Findings weaknesses in management of environment

• Write-up weaknesses in three parts
• Relevant facts, observations, and potential
  consequences
• Identified weaknesses in the way environment is
  being managed which needs to be addressed
• Clause of the EHS standard

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Review of business performance and senior
management involvement

• Seeking to understand
• Business and broader operations context which
  will hugely influence every aspect, including EHS
• Where they see their greatest strengths in
  mainstream activities
• Business status and developments which will
  impact environment
• Where is EHS program in the context of the
  challenges and changes they are addressing in the
  broader business?
• Are managers aware of EHS issues on the ground?

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Review of business performance and senior
management involvement

• Find out from senior management
• Operational performance trends
• Why they think these trends are occurring
• Key changes to the business budgets, personnel,
  etc.
• Major business challenges current and projected
• Most exciting developments
• How do they harness untapped potential?
• How do they regard their EHS performance?
• Tell them what the auditors have discovered so
  far
• Are they surprised by these findings?
• Why do they think they are arising?

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Environmental management review

• Top-down analysis
• Seeking understanding (for auditors and managers)
  
• techniques management use to drive the operations
  
• extent to which they use (or dont use) these
  techniques to drive environment
• Use management system standards as an agenda for
  a discussion mostly with mainstream management
  (1.5 hours each) end 10-12 hours total.
• Where appropriate populate the discussion with
  issues observed on site

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Meeting with senior person

• To allow them to
• come to terms with the assessment conclusions
  prior to the closing meeting
• better use of the closing meeting
• Give recognition (where it is really warranted)
  to what works well in mainstream operations
• Describe more substantive observations and
  potential consequences
• Provide feedback on main causal factors
  identified
• Discuss the closing meeting and how they can use
  it to establish a leadership position on the
  issues identified

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Closing meeting

• Review of approach
• Focus on operations, people, processes (real
  ones), and practice
• Review of audit goals
• Can management be comfortable with the way they
  are looking after this aspect of the operations
• What you have seen - photos
• Select photos which are not ambiguous and are
  broadly representative (multi media, risk
  control/compliance/unnecessary impact, multi
  functions and departments)
• Talk to consequences for the business and its
  management
• Start and finish with something serious
• Message its not ok (where its not)

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Closing meeting

• Feedback main causal factors identified
• Ensure that management team understands the
  MANAGEMENT causes
• Tell them they are accountable for fixing it
  (environmental function can facilitate)
• Discuss next steps
• fixes for observed issues
• changed management behaviour to address causes
• follow through by the auditors

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Good audits will

• Reveal how it really is
• Induce serious management engagement and
  behavioral change
• Deliver improved and enhanced outcomes
• Get the auditee to look beyond the issues
  identified in the audit
• they found these what else is out there
• How do we stop these issues from recurring

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Good audits will

• Drive sustained performance improvements (better
  outcomes)
• less accidents and incidents
• higher levels of compliance with regulations
• reduced impact on people and the environment
• Provide value to the business way in excess of
  the costs

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Audits will be good

• If the auditors employ the right style and
  personal approach
• If auditors employ an effective methodology
• If all involved use it as an instrument of
  behavioral change
• Bring the auditors to the areas where its worst
• Use the auditors to engage management in the need
  to drive environmental aspects
• Help them to maximize the use of their time
• If auditees have used it to move EHS management
  in a much enhanced way

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Summary of Auditing Process

• Communication before the assessment
• Opening meeting
• Site tour
• Root cause analysis
• Business performance review
• Environmental management review
• Meeting with top person
• Closing meeting

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Construct All environmental outcomes are a
product of management and operator behaviors