Establish Strong Management Systems

Create a proactive safety culture where leadership visibly commits to EH&S priorities. Assign clear responsibilities and accountability at all levels, and allocate adequate resources for safety programs. Regular management reviews of EH&S performance help identify issues before they become audit findings.

Implement a formal audit preparation program with internal audits conducted quarterly or semi-annually. Use the same standards external auditors will use, and treat internal findings seriously with documented corrective actions.

Master Documentation and Record-Keeping

Develop standardized templates for all required documentation and implement a centralized system (digital is ideal) for storing and tracking records. Key practices include:

• Maintain complete training records with dates, topics, trainers, and attendee signatures
• Keep all permits, licenses, and certifications in one location with expiration tracking
• Document all incidents, inspections, and corrective actions thoroughly
• Establish retention schedules that meet or exceed regulatory requirements
• Conduct regular document audits to identify gaps

Prioritize Training and Competency

Create a comprehensive training matrix identifying who needs what training and when. Ensure training is:

• Job-specific and hazard-based, not just generic
• Documented with attendance records and comprehension verification
• Refreshed at appropriate intervals (annually at minimum)
• Provided before employees start work with new hazards
• Tracked with automated reminders for renewals

Verify competency through observations, quizzes, or practical demonstrations.

Maintain Robust Hazard Communication

Conduct thorough chemical inventories and ensure every chemical has a current SDS readily accessible to employees. Implement clear labeling protocols with regular inspections, and train employees specifically on the hazards they work with. Secondary containers must be properly labeled, and your written hazard communication program should be current and accessible.

Implement a PPE Management System

Conduct formal PPE hazard assessments for each job role and document everything. Establish clear standards for when and where PPE is required, provide adequate supplies, and train employees on proper use, maintenance, and limitations. Conduct regular inspections to ensure compliance and replace damaged equipment immediately.

Ensure Emergency Preparedness

Develop comprehensive emergency action plans and conduct regular drills. Keep emergency exits clear with visible signage, maintain and inspect fire extinguishers monthly, stock adequate first aid supplies, and ensure employees know evacuation routes and procedures. Post emergency contact information prominently.

Stay Current with Regulations

Assign someone to monitor regulatory changes and updates. Subscribe to OSHA, EPA, and relevant state agency notifications. Join industry associations for updates and best practices. Conduct annual compliance reviews against current regulations, and consult with EH&S professionals or legal counsel when regulations change.

Develop Strong Programs for High-Risk Areas

For common problem areas, establish formal written programs:

• Lockout/Tagout (LOTO)
• Confined space entry
• Respiratory protection
• Hearing conservation
• Hazardous waste management
• Spill prevention and response

Each program should include procedures, training requirements, and documentation protocols.

Implement Continuous Improvement

Use a systematic approach to corrective actions with root cause analysis, not just quick fixes. Track trends in near-misses, incidents, and audit findings. Conduct regular management reviews of EH&S metrics. Encourage employee reporting without fear of retaliation, and celebrate safety successes to reinforce positive behaviors.

Conduct Pre-Audit Reviews

Before external audits, walk through facilities with fresh eyes, review all required programs and documentation, verify employee awareness through informal interviews, and check that all corrective actions from previous audits are complete and documented.

Key Success Factors

The most critical elements for avoiding audit failures are:

• Consistency – Apply standards uniformly across the organization
• Accountability – Hold people responsible for their EH&S duties
• Documentation – “If it isn’t documented, it didn’t happen”
• Employee engagement – Involve workers in safety processes
• Continuous monitoring – Don’t wait for audits to find problems