When was the last time you were involved with a regulatory body? I can remember a time when a millwright was involved in an incident in our maintenance shop. He was using a 20″-disc grinder when the piece of steel he was grinding got caught and pulled his hand into the grinding wheel. He was off for a quite a few weeks, but he did not sustain any long-term injuries.
Well the next day, the Ministry of Labour was in the plant to investigate the incident. When they arrived, they reviewed the accident report, the disc grinder (which had been locked out and barricaded off), and wanted to see the maintenance records of the disc grinder.
The Ministry of Labour asked me (without looking at the records), how often we maintain that disc grinder (and the other pieces of equipment in our maintenance shop), and what we do specifically for the maintenance. I responded that we do a weekly inspection of all of our shop equipment, inspecting guards, e-stops, gaps, etc. The inspector asked, with an indication that he would not be impressed with our records, to see the last four inspections.
I grabbed a binder off of the shelf and flipped to the maintenance shop inspection. There were the records for the past ten months, each with the inspection date, the individual who completed the task, inspection procedures and all as-found and as-left information regarding any gaps between the rest and the grinding wheel. The last inspection was completed a day before the incident and indicated that the gaps were a bit large at 3/16″ and was closed to 1/8″.
The inspector looked a few of the records and said “These are some of the best records I have seen for shop equipment. You have nothing to worry about, your program is great, and you are doing your due diligence.” With that, he left, and I have never seen him again. Our records were able to prove that we were doing everything as reasonably as possible to minimize the risk to our employees. This was a great feeling, as in Canada, supervisors, managers, and the company can all be fined or jailed if they are found to not have the right programs in place which result in injury or death. At least I knew we had the right precautions in place.
Are You Audit Ready?
I have a feeling the only reason we were not fined in the incident above, is that we not only had the maintenance records, but they were organized and readily available. I believe that the records were “audit ready” as they were organized and quickly accessible. While organizations may the appropriate records, are they kept in a way that makes quickly accessible?
When auditors and inspectors asked for records, they expected them quickly. If not, they begin to wonder how unorganized the organization is, or what they are hiding. This is why I advocate that any organization I work with have an Audit Ready program in place.
What is an Audit Ready Program?
An “Audit Ready” program is a maintenance program that maintains complete and accurate records and documentation that is easily accessible and organized. An Audit Ready program typically will have the following;
- Maintenance records for all equipment/activities with dates of completion, who completed the work, what was found, what was corrected and any follow-up work initiated
- A Records Retention policy
- An organized manner of keeping all documents (hard and soft copies)
- An overview of what PM activities take place at what frequency
- A defined location for keeping all hard and soft copies of certificates (think pressure vessel certificates, elevators, etc.)
- Having the team trained in the Record Retention policy and where all of the records can be found
- Have a method to flag regulatory inspections that are coming due.
Having these elements in place will go a long way to making sure that in the event of an auditor, inspector or regulator showing up, that your organization is perceived as organized and competent.
So, is your maintenance program audit ready and will it survive an inspector? How do you keep your maintenance records organized and quickly accessible? Do you capture the as-found and as-left measurements? If you feel your maintenance program is not audit ready and needs to be, contact info@eruditio.com to see how we can help you.
Disclaimer: These elements are based on our experience and apply to most industries. Eruditio, LLC must insist that any organization looking to improve their record keeping takes into consideration any local, state (or provincial), federal and regulatory body requirements.
Remember, to find success; you must first solve the problem, then achieve the implementation of the solution, and finally sustain winning results.
I’m James Kovacevic
Eruditio, LLC
Where Education Meets Application
Follow @EruditioLLC
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