Reviewing Documents

Reviewing documents is definitely not the most interesting part of conducting audits.  At least for me.  But it is a very necessary part.  We review documents because it gives us information and helps us verify other information in order to produce evidence.  As an auditor, we need to review documents as we audit, not just to give us information to verify against, (i.e. Does the operator follow steps 1, 2 & 3 correctly?) but we have to critically review each document as well.  I like to use the basics and use them well.  For reviewing documents, I like to use the 5Ws and H, just like we learned in school.

Who – A document must clearly identify responsibilities for every task.  I don’t know how many procedures I have read, that clearly describes the task, but no where does it indicate who is suppose to do it.  “It’s obvious, it’s suppose to be operator ABC!”  Obvious to the writer, not the reader.  Procedures are for the readers, who are usually new to the task or job and use the procedure for training.

What/How – The tasks or steps in a procedure need to be logically documented.  Make sure critical steps are not missed.  Can the procedure be written in a better format (i.e. flowchart versus straight text)?  Does it address all of the required information?  When it comes to EHS audits, a lot of the time, legal requirements must be considered, and therefore specific requirements may be required to be included.  For example:  activities being carried out above a specific height may require fall arrest equipment to be worn.

Where – It must be clear that the scope of the activities in the procedure is clearly defined.  Is the procedure applicable to the entire site or just the maintenance department?

When – The triggers for a procedure need to be defined.  Is the task based on a regular schedule (i.e. monthly) or is this activity only occur after another one is finished (i.e. New Chemical review procedure is only required when someone decides to being in a new chemical).

Why – There needs to be a clear purpose for the procedure.  The procedure may not necessarily document the purpose within the procedure, but when reading it, there needs to be a clear purpose.  Because if there is no purpose to having this document, then it’s a waste of time and energy for everyone.  Because all documents must be controlled and regularly reviewed and revised as necessary.

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