Equipment Compliance AuditA product compliance audit is a hands-on review of an exemplar product, such as a piece of agriculture or construction equipment. Design features are observed, comparing them to the technical provisions identified in standards and regulations from OSHA, ISO, ANSI, etc.

The goal, after all is said and done, is to make sure a product meets or exceeds the intent of all relevant safety standards.

“I have conducted many product compliance audits over my career,” said Mike Senneff of Product Safety Help, a consulting and training firm specializing in product safety and compliance, who shared his insights at AEM’s recently held Product Safety & Compliance Seminar. “The nice thing is that the process does not change from one product to another. All that changes are the industry standards involved.”

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When a Compliance Audit Can be Beneficial

New product launch. According to Senneff, it is often a good idea to take one more detailed look at a new piece of equipment before sending it to market.

Product acquisition. If your company has acquired another company or some of its products, it’s a good idea to audit those products to make sure they meet safety standards. In many cases, you can never be sure what the other company has or has not done to ensure compliance.

Fear of the unknown. Senneff said a manufacturer may sometimes have doubts about what industry standards should be applied to their own company’s products.

“I had a manufacturer ask me to conduct a product compliance audit on one of their off-highway machines,” he said. “I sat down with the manager of product engineering because I needed to know which standards had been applied to the product. The manager told me that no standards were being applied to anything. This company was simply following what their main competitors were doing. In a situation like this, a compliance audit is a very good idea.”

International markets. According to Senneff, a product compliance audit can provide useful backup documentation for inclusion in a manufacturer’s EU Technical Construction File, as well as its Australian OHS (Occupational Health & Safety) attestations.

Essential Tools to Conduct an Audit

The product. An auditor obviously needs an exemplar product that can be examined. Senneff said this could be a finished product off of the assembly line or a prototype nearing production.

“The auditor may have to operate certain machine functions such as lighting and engine start interlocks to ensure compliance with relevant safety standards,” Senneff explained. “That said, there is no need to completely operate a machine on a jobsite or anything like that. Functions like brakes and steering should be evaluated separately as part of that product’s safety risk assessment.”

Standards. An auditor needs copies of the relevant standards by which the product must comply. Senneff said that even in today’s digital world, where documents can be stored on a laptop, tablet or smartphone, a three-ring binder still works very well. He said he especially likes the fact that he can write notes on the pages and quickly flip back and forth as necessary.

Digital camera. Photographs help document the overall configuration of a machine as well as specific features. Photos are also helpful when writing the audit report, particularly if there is a non-compliance issue. For example, a safety standard may specify that a positive battery cable must be protected and insulated. A photo helps document that.

Tape measure. When conducting a compliance audit on a piece of equipment, several items need to be measured because various safety standards must be met for specified heights, widths, distances, etc.

Digital calipers. Senneff said this is another useful tool when taking certain measurements, such as the thickness of handrails where safety standards may specify a certain diameter.

Digital scale. Some safety standards specify that the force required to swing a ladder or open a hood, for instance, cannot exceed a certain amount. A digital scale will help measure that.

Slope indicator. Some safety standards establish that the difference between a ladder and staircase is distinguished by the angle to the ground.

“A slope indicator tells you how many degrees an angle is,” Senneff said.

SIP (seat index point) locator. According to Senneff, this isn’t necessarily an essential tool, but can definitely come in handy when measuring for things like headroom clearance in a cab.

Operator’s manual. A thorough review of the operator’s manual must be part of the product compliance audit. Senneff said he sometimes finds non-compliant safety symbols and language derived from safety standards. Furthermore, in many cases there is a standard that specifies the form and content of an operator’s manual. 

Assembling the Report

According to Senneff, physically conducting the product compliance audit will typically take around eight hours. However, an auditor’s work is not done when the physical audit is completed. Writing the report is next.

In his product compliance audit reports, Senneff explains every clause from the relevant standards along with his findings on the product. If everything checks out on a certain clause, he noted that he writes, “no design revision necessary.” But if there happens to be a non-compliance issue, Senneff said it’s important to make your explanation easy to understand.

“Explain what the standard clause is calling for,” Senneff said. “That way the person doesn’t have to spend time looking it up themselves. Also explain what is needed to meet the standard. Then recommend a design change be considered by the manufacturer. Do this clause by clause. Use tables and other formatting techniques to make it user-friendly.”

Out of respect for the product designers, Senneff noted he likes to use the phrase, “considerations for design revision,” rather than something harsher such as, “design revision needed.”

“I might not be aware of all the circumstances and reasons why a certain design feature was designed the way it was,” Senneff related. “I don’t want to assume that something is out of compliance due to an oversight or mistake. I prefer that product designers read my report, and then get together to come up with their own potential revisions.”

Reacting to Non-Compliance Findings

When a non-compliance issue is discovered during an audit, Senneff said a series of events should be triggered.

As discussed above, minor issues can be identified in the report, placing responsibility with the design team to determine what to do about them. A good example is a standard that says the first step on a cab-access ladder should be no more than 550mm from the ground. You grab your tape measure and determine that the first step is 560mm. It’s a small discrepancy, but a discrepancy, nonetheless.

“It’s a good idea to bring that to the designers’ attention,” Senneff pointed out. “But is there really a higher likelihood that someone will fall or get injured? Probably not. Yet, at the same time, if someone does fall and there is a lawsuit, there could be a chink in the manufacturer’s armor. This is the type of thing manufacturers and product compliance auditors always need to be weighing.”

More significant non-compliance issues warrant a closer look from product designers. Any immediate threat to safety would fall into this category.

“Product designers may actually decide that a running design change is needed as soon as possible, along with a field modification initiative,” Senneff said.

An example is a power transmission part. A safety standard might specify that power transmission parts must be guarded on a machine. A product compliance audit finds that a rotating shaft is unguarded and left within reach of someone standing on the ground. Perhaps there is a valid reason why that shaft has been left unguarded. On the other hand, this could be an oversight that creates the need for a more thorough safety risk assessment of the machine. Those types of decisions must be made by the manufacturer. The auditor’s job is to point out the fact that decisions need to be made.

Senneff said he regularly finds the following non-compliance issues when auditing heavy equipment:

  • Safety sign formats
  • Access ladder dimensions
  • Roadway lighting and marking components
  • Missing battery post insulation
  • Missing tie-down points
  • Inadequate access to elevated service locations (i.e., grease points or fluid reservoirs)

“Anytime I audit a machine, I’m sure to find three or four items on that list,” Senneff related.

Senneff was also quick to point out that a product compliance audit is no substitute for a complete product safety review and risk assessment. That is because a compliance audit just looks at the relevant safety standards, and safety standards are not intended to cover every conceivable hazard. That is what a safety and risk assessment is designed to do.

There is also one potential downside to a product compliance audit: If there ever is an incident in the field with a product that has non-compliance issues, there is documentation. That’s why it’s so important for the auditor to prepare a thorough report. Then it’s up to the manufacturer to take appropriate actions based on what the report tells them — before an incident takes place.

AEM Safety & Product Leadership

"Do it once, do it right, do it globally" has been the longstanding motto of AEM’s Safety & Product Leadership Department, and it guides efforts to address ever-increasing global demands on equipment manufacturers to develop machines that are safe, productive and compliant. To learn more about AEM’s Safety & Product Leadership activities, visit https://www.aem.org/safety-product-leadership. To learn more about AEM’s Product Safety & Compliance Seminar, visit https://www.aem.org/events/conferences-and-webinars/product-safety-compliance-product-liability.

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