Layered Safety Process Audits A New Way to Strengthen Safety Systems By James A. Burk and Abigail Sprague Alayered- safety process audit (LSPA) is a systematic auditing technique used to evaluate critical safety systems. An LSPA is conducted by employees who represent various levels of the organization. Traditionally, safety has relied on various inspections,ons specific to programs or equipment. Often, however, these inspections are assigned to a few individuals who reside at the same level within the organization (e.g., safety technicians, production, and maintenance employees). Relying on a select few to conduct inspections can result in process errors and gaps due to limited knowledge or poor technique, gaps in the inspection process itself, and inconsistent application of inspection protocols. Because so few individuals are involved, these system errors may not be readily identified, thus creating organizational risk. An LSPA is not the same thing as a layered process audit (LPA), which is a specific processr’term used within the quality profession. An LSPA is specific to safety processes and systems. How— ever, its logic, techniques, and value mirror that of an LPA. From LPA to LSPA Like an LPA, an LSPA enables plant management at different organizational levels to directly evaluate the effectiveness of safety programs and any related critical processes. The LSPA process can apply to any safety process, but it often helps to first focus on safety—critical programs, such as those in which a gap or error can result in severe injuries, disabling injuries, or fatalities. Safety programs with these levels of consequences include confined space entry, hazardous energy control (lockout! tagout), powered industrial vehicles, machine guarding, driving safety, fall prevention protection, electrical safety, and life safety (e.g., emergency exits, exit routes, emergency lighting) Initially focusing on safety—critical programs and the related processes (e.g., entry permits, lockout procedures for maintenance, anchor points) can produce immediate, positive improvements in an organization’s injury or fatality experience. As a next step, an organization can expand the LSPA process to encompass programs that contain gaps or produce errors that can lead to injury (but do not necessarily immediately result in fatalities), such as hearing conservation, PPE, and hazard communication/chemicals. Over time, the LSPA process is applied to a facility’s entire safety management system. By including plant leadership at all levels (especially senior leadership), this process fosters a positive safety culture. Create & Conduct an LSPA The first step is to define a facil— ity’ s LSPA method in writing. This document should define LSPA goals, Layered safety process audits enable plant management at different organizational levels to directly evaluate the effectiveness of safety programs and any related critical processes. identify stakeholder roles and responsibilities, and describe the mechanics of the process. The detailed description of the process should identify what safety process will be measured and how it will be measured; specify the frequency of measurement and by whom; explain how to document identified process gaps (opportunities for improvements); and indicate how the organization should address and track these issues to completion. The roles and responsibilities component will also define the training, qualifications, and knowledge of the individuals involved. To ensure consistency, the document should include the necessary forms. For the process to be most effective, all levels (or layers) of the organization must participate in the LSPA; this includes primary employees, frontline supervisors, middle management (e.g., area managers), and senior leadership, including the plant manager. As with an LPA, it is best to create a frequency schedule based on the rate of occurrence of a critical process. Here is an example: Primary employees and frontline leaders will participate in FrolauimralSalety NOVEMBER 2017 www.asse.org in the LSPA process each day, middle management will conduct an LSPA once a week, and senior plant leaders will conduct an LSPA once a month. Some safety—critical processes do not occur on a daily basis, so auditing fre— quency must be modified accordingly. For example, confined space permitting may not occur each day. Therefore, the team might set LSPA frequency as follows: an LSPA is performed for every fifth confined space permit entry at the supervisor level; every 15th permitted entry is audited by middle management,- and every 30th permitted entry is audited by the plant leader. Once the LSPA method is defined, the safety team must develop and provide training to all participants so that the process is applied consistently and as designed. This training should include hands—on group practice to confirm a minimum level of performance among auditors. After applying LSPA to the first selected safety—critical program process, an organization should review the results. Are the audits identifying known or casually observed gaps? Are auditors formally documenting, addressing, and tracking identified issues? Management should watch for red flags, such as results from one individual or group that always finds no gaps. Some individuals or groups may fear that identifying gaps will penalize others or that gaps will lead to negative consequences. The organization should clearly state that identifying gaps is a positive outcome because doing so represents an opportunity for improvement. Any improvements made will eventually yield a robust safety process that strengthens the plant’s safety performance. The Value of LSPA An LSPA aims to improve systems and does not dwell on fixing employees. An LSPA is focused on evaluating safety systems as a whole and answering several questions: Is the process occur— ring when required? Are required forms being used, and are they used accurately and completely? Are the forms collect— ing the information needed to achieve the desired results? Are identified gaps well documented, including the use of corrective action plans, and the assigning of individuals to monitor corrective