Overview of the National Audit Tool (NAT)

The National Audit Tool (NAT) has been developed in conjunction with federal and state statutory regulator representatives to provide consistency and harmonisation for OHS requirements relating to Australian self insurers across multiple jurisdictions.

The NAT defines auditable criteria (with supporting information) to be used by state regulators in conducting audits of self insured organisations.

Overview

The NAT provides informative criteria for self insurers in addition to the auditable criteria used for verification activities. This information relates to the application of the NAT in a broader context and provides detail with regard to the following subject areas:



Auditing Occupational Health and Safety Management Systems by Regulators: This is a "How To" approach to these important audits, explaining the methods and objectives of the NAT.

Audits, inspections and legislative compliance: Critically, it also explains that the NAT is not itself a workplace inspection system,.

Auditors: The NAT sets out the operational context of auditors roles, and cites The AS/NZS ISO 19011- Guidelines for quality and/or environmental management systems auditing as the audit standard.

Self-audit programs: The NAT sets out a practical framework for self insurers to create and conduct effective internal audits, including:


Establishing an audit team
Defining audit roles
Setting up a reliable reporting and documentation system
Creating an effective oversight mechanism which will enable proper assessment of conformance with regulatory requirements
The User Guide and Workbook are designed to provide regulators and self insurers with operational benchmarks and common references.

OHS Management Systems approach

The NAT, by its nature, requires that an OHS Management Systems approach is adopted by self insurers to meet the NAT's auditable criteria. The NAT relates to operational principles, rather than setting out pro forma, specific requirements for auditable criteria. OHS management requirements for individual businesses can vary widely, and each organisation must create its own version of these audit processes, in relation to its circumstances.

The NAT is comprised of five key "Elements" with sub element components where more specific auditable criteria relate to a subject area. The identified elements are consistent with best practice contemporary management system structures and include the following:

Element 1: Health and safety policy

This element usefully defines the critically important areas of health and safety management and operational functions to which the organisation must commit itself.

These areas effectively create a comprehensive policy base, including:


Risk management
Health and safety legislation
Objectives improving injury and illness prevention
Health and safety training
Inclusive employee consultation
Dissemination of health and safety information to all people in the workplace
Effective implementation of organisational health and safety policies
It will be seen that each of these policy areas integrates into full coverage of essential OHS management practices. The idea is to create a fully functional, "customized" health and safety policy for organizations to manage themselves.

(NAT auditable criteria also include administrative arrangements in relation to access and maintenance of the Health and safety policy. )

Element 2: Planning

The Planning element includes very useful information and a good description of absolutely essential aspects of OHS management operations which must be addressed to ensure good practice. It relates directly to addressing legislative requirements that apply to an organisation systemically, identifying the tools used to achieve corporate objectives and targets through health and safety management plans.

Element 3: Implementation

Element 3 is an excellent example of how the audit process operates and targets key areas of functionality. It provide good reference points for self insurers to approach their own audits meaningfully and with due attention to the vitally important areas of policy and planning.

Implementation defines auditable criteria relating to:


People (resources, responsibility, accountability, consultation)
Administration (documentation, data control and operation)
Programs, tasks and activities in the workplace including risk management, risk prevention and mitigation, dealing with emergencies (e.g. Contractor selection, design control, workplace facilities etc).
Knowledge base (includes recruitment and contractors)
Training and verification of both competency and understanding of training (critically important for operations)
Communications, notification processes, consulting with staff and reporting (covers the entire implementation area to ensure effective operation at all levels)
Specific workplace needs and operational procedures
Risk management and risk elimination including public safety, hazard handling, identification, high risk permits and risk control plans
Maintenance, faulty plant and equipment and repair issues
Product risk controls and tracking
Emergency operations and response, critical incident management
Element 4: Measurement and Evaluation

This section of the NAT is a virtual map of references to management operations in relation to health and safety management. Measurement and evaluation relates to methods used to evaluate and verify workplace programs, tasks and activities continue to meet organisational needs. Provision is also made including:


Verification activities (including various types of inspections and audits)
Incident investigation (including causal analysis)
Dealing with corrective and preventative action
Records management (used to provide evidence and a mechanism for evaluation of content)
Legal issue management and conformance issues
Management of audits
Direct management interaction with the audit process
Element 5: Management Review

This element defines the role of senior management reviewing the performance of the organisation in meeting its legislative requirements organisational commitments. It also provides a requirement for actions to be developed to address improvements opportunities that have been identified as a result of this review.

Criteria application

The NAT itself defines structured auditable criteria for use by the relevant state regulator and those that participate in programs where compliance is required.

The NAT also provides criteria and useful information relating to the auditable requirement, to allow broader understanding of the scope of application to which the criteria relates. It effectively spells out the audit issues and functional requirements for self insurers.

Additional information contained within the NAT includes examples intended to be used only as guidance to assist in understanding some typical questions or evidence that may be used in the verification process.

Common Problems

Understanding and interpretation of auditable criteria appears to be a common issue where non-conformance is identified. Converting auditable criteria into a process requires an understanding of the application

of OHS requirements in a practical context.

The most important function of the NAT Elements is to clearly describe a broad approach and identify critical principles involved in health and safety management. The NAT Elements are a good basic guide to OHS management issues, andalthough these issues have to be applied to specifically to organisations on a needs basis, the NAT provides a clear indication of structure and the basis of audit criteria.

NOTE:Conformance to the audit criteria alone does not assure compliance with all statutory obligations nor does it preclude any action by a regulatory body.

That's a quote from the NAT preface materials. It's strongly advised to seek professional guidance regarding these obligations to ensure all areas of liability are properly covered.

Lane Safety Systems offers safety consulting, risk management, compliance management and safety management systems for self-insured businesses across Australia. For more information, visit Self Insurance