PSM Audit Procedures Manual
Southwest Louisiana Construction User’s Council
June 15, 2004 – Rev # 3

1.0 INTRODUCTION

The Pre Qualification Form and the Audit Process are key management tools for achieving consistency in implementation and utilization of a common approach to meeting certain requirements of OSHA 1910.119. The PQF serves to provide the minimal information on general Safety, Health & Environmental performance needed for each participating owner company to make decisions relative to the contractor’s compliance with their individual company standards. The PQF also provides a standard methodology to track each contractor’s compliance with the Craft Skill Certification Policy as established by the SLCUC.

The audit process is the mechanism used to identify areas requiring attention and to verify that the various elements listed within the PQF are in place and are achieving the requirements stipulated within the PQF.

This Audit Procedure Manual provides the guidelines for performing the audits. The manual is a tool to ensure that all audits are performed objectively, consistently and accurately. Contractors, who submit and maintain a current PQF, may use these guidelines for carrying out self-audits.

The most current edition of the SLCUC Audit Procedures Manual, as approved by the SLCUC Oversight Committee, shall be the document in use by the Safety Council of SWLA in administration of both the PQF process and the PQF Audits.

The results of these audits are available on the secure PQF web site to SLCUC member companies in good standing.

2.0 SCOPE

This Audit Procedure Manual establishes basic audit principles, criteria and practices for establishing, planning, carrying out and documenting audits of the PQF submitted by contractors. It also provides guidelines for verifying the existence and implementation of the elements of the PQF.

3.0 DEFINITIONS

Audit

A systematic and objective examination to determine whether information contained within the submitted PQF and related attachments are in fact complete and in compliance with specific OSHA regulations and/or comply with established SLCUC requirements.

System

The Safety Council of SWLA provides the organizational structure, procedures, processes and resources for implementing the PQF Audit Process.

SLCUC- Southwest Louisiana Construction User’s Council

The organization, establishing the criteria for the audit, including the frequency, and the criteria for closure of findings. The SLCUC has created a specific oversight committee to assure the process is evergreen and evaluated on a set frequency. This committee has the final say regarding conflicts, which may arise because of an audit or closure of a finding. The committee is the authority for making changes to the PQF, the Audit Procedure and all other aspects of the program.

Auditor

A person, who has the qualifications and authority to perform the audit. The SLCUC has stipulated that the Auditor(s) must have extensive experience in the Safety & Health field, experience and training as an Auditor; a working knowledge of OSHA & DOT regulations and be familiar with the Petro-Chemical Industry.

Auditee

The organization, (contractor) to be audited.

SLCUC Audit Checklist

A checklist designed for use during an audit derived from the current PQF form.

Safety Council Southwest Louisiana

The organization that is responsible for hosting the secure web site for the PQF and Safety Audits, for managing the day-to-day PQF activities and conducting the PSM Audits. The Safety Council is answerable to the SLCUC in the defined responsibilities.

Findings

The failure to produce acceptable documentation of compliance with specified requirements.

Corrective Action Request (CAR)

Elements of the PQF, which fail to meet requirements, will be documented, as a finding and a Corrective Action Request (CAR) will be issued. CARs are used to identify departures from the requirements. When a CAR is issued, the Auditor will also provide minimal guidance on the steps necessary to close the finding. The contractor has the right to challenge any finding, first with the Auditor and if necessary with the SLCUC Oversight Committee. Closure of a Corrective Action Request should become a priority for achieving the requirements of the PQF/Audit Process to remain in good standing with member SLCUC companies. CARs require written documentation from the Auditee stating that the deficiencies have been corrected with specific details of how the corrections were made and the date of implementation. CARs may require a follow-up audit to be performed. Corrective actions implemented, as the result of a CAR may be verified for effectiveness in meeting the specified requirements.  This will be done by request only.

Objective Evidence

Qualitative or quantitative information, records, or substantiated statements of fact, pertaining to an item or service, or to the existence and implementation of an element of the PQF. Objective evidence is based on verifiable observations, measurements or tests.

4.0 CHANGES TO THIS DOCUMENT

Any suggestions for changes to this document are to be forwarded to the Oversight Committee; the committee will recommend approval or disapproval to the SLCUC Coordinating Committee. Implementation of changes to this document shall be posted on the web site with a revision date noted.

5.0 AUDIT OBJECTIVES

Audits are designed for one or more of the following purposes:

  • To determine the conformity or nonconformity, with SLCUC requirements, of the system elements specified by the PQF and associated attachments.
  • To determine compliance with the Skill Certification Policy as established by the SLCUC.
  • To provide the auditee with an opportunity to improve their system.

The Auditor’s responsibilities include:

  • Preparation of the Audit Plan.
  • Complying with all audit procedures and protocols.
  • Communicating and clarifying audit requirements.
  • Planning and carrying out assigned responsibilities in an effective, efficient and professional manner.
  • Documenting Corrective Action Requests, as applicable.
  • Reporting the audit results to the contractor and placing the results on the Safety Council website as an attachment to the contractors PQF.
  • Verifying the effectiveness of corrective actions,
  • Safeguarding, compiling documents and information pertaining to the audit, specifically.
  • Submitting documents as requested ,
  • Ensuring confidentiality, and treating privileged information with discretion.
  • Closing the audit.

6.0 EXECUTING THE AUDIT

  • The Safety Council Auditor will make direct contact with the contractor and arrange a mutually agreeable date for the audit and provide a listing of pre audit materials needed, if appropriate.
  • Opening Meeting - Each audit starts with an opening meeting, referred to as the Pre-Audit Conference. The purpose of this meeting is to:
    • Introduce the auditor to the auditees' management.
    • Review the scope and objectives of the audit.
    • Provide a short summary of the methods and procedures to be used to conduct the audit.
    • Establish the official communication links between the auditor and the auditee.
    • Confirm that the resources and facilities needed by the auditor are available.
    • Confirm the time and date for the closing meeting and any interim meetings of the auditor and the auditees' management.
    • Clarify details of the audit plan.

7.0 COLLECTING INFORMATION

Information is collected through interviews, examination of documents, and observation of activities and conditions. Information gathered through interviews should be tested by physical observation, measurements and records.

8.0 CLOSING MEETING

At the end of the audit, prior to preparing the audit report, the auditor will hold a meeting with the auditees’ management and those responsible for the functions audited. This meeting is referred to as the Post-Audit Conference. The main purpose of the meeting is to present audit Corrective Action Requests, if applicable, to ensure that they clearly understand the results of the audit activities to date.

The Auditor, after presenting the evidence and observations of the audit, will explain the next steps to closing the audit. If Corrective Action Requests are to be issued by the Auditor and signed by the auditee’s responsible manager, as evidence of understanding the corrective action needed.

Records of the opening and closing meeting, including attendee lists, are to be maintained in the audit file until the audit is deemed to be closed by the auditor. Upon closure of the audit, these records will be provided to the Safety Council Administrator. The Audit Report, completed CAR forms, closure activity, and follow–up audits for closure of findings will be maintained as attachments to the contractors PQF or the Administrators files.

9.0 ETHICS

The Southwest Louisiana Construction Users’ Council (SLCUC) and the Safety Council of Southwest Louisiana acknowledge the value and importance of the PQF/Audit Process and recognize the responsibility inherent in the process and its consequent applications. Owners and Contractors are encouraged to exercise the highest standards of ethical behavior in whatever involvement they may have with the process. All users of the system are thus encouraged to respect the rights and dignity of others; to be honest, accurate and open-minded in the presentation of information and ideas; to insure privacy and confidentiality in dealing with each other; and to prevent and avoid any situation where a conflict of interest may compromise the capacity for making prudent and objective decisions and responses.