Auditing Elements: Incident Investigation, Emergency Response, & IIPP (Part 9)

In this compliance audit blog series, we have decided to focus on each program element. If you plan to lead an audit, these lists will be instructional for you. But if you want to prepare for an upcoming audit, these lists will give you an idea of what to expect.

There is much disagreement in the process safety world regarding the definitions of words like “incident” and “emergency”. This explains why one employee may want to report valve that is barely weeping while another might not understand why a leak that caused an evacuation would need to be reported. For these reasons, when I conduct an audit, I don’t start by saying what is required. Instead, I ask questions like, “Have you had any small releases of the chemical?” or “Have employees every complained of a smell of the chemical?” If you start with a question like, “Have there been any incidents which you didn’t investigate?” Most people will automatically answer, “no.” But, by starting the discussion around small incidents, people are likely to open up about what is actually being done.

Incident Investigation

Here are some ideas for auditing completed incident investigations:

• Is there a list of findings from the incident?
• Locate the associated documentation or field-verify any incident investigation recommendations.
  • If additional training was required, is that training record available?
  • If a component needed to be replaced, was it replaced?
• Look for documentation showing operators have been trained on past incident investigations.
• Were the mandatory notifications made promptly?

Emergency Response

Similar to auditing incident investigations, auditing the emergency response program can be hindered if the team is using different definitions of “emergency”. It should first be determined if the facility is considered a responding or non-responding facility. If the facility is relying on local first responders to lead emergency operations, the requirements for their program are easier. Here are some ideas for an auditing an emergency response program:

• Ask an operator what he (or she) would do if he were in an area where a large release started. It is surprising how many operators at non-responding facilities answer this question as if they are considered responders!
• Locate documentation showing all facility personnel have been trained on the hazards of the covered chemical.
• Locate any documentation showing evacuation or shelter-in-place drills.
• During the site walkthrough, observe if there are adequate windsocks and evacuation maps posted. Paths of egress should also be clear.
• In the written emergency response program, is all information accurate? Are the contact names and phone numbers current?

Injury & Illness Prevention Program

For facilities in California, an audit of the injury and illness prevention program (IIPP) should also be conducted. This pairs well with auditing the emergency response program. The written program should be audited for accuracy and periodic safety inspections should also be completed.

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This is Part 9 of a series on compliance audits. You can access previous blogs in this series below:

• Part 1: Compliance Audit Overview
• Part 2: Compliance Audit Team & Sessions
• Part 3: Compliance Audit Documentation
• Part 4: Auditing Elements: Process Safety Information
• Part 5: Auditing Elements: PHA, Compliance Audit, & Employee Participation
• Part 6: Auditing Elements: Operating Procedures & Training
• Part 7: Auditing Elements: Mechanical Integrity
• Part 8: Auditing Elements: MOC & PSSR