Audit, Traceability and Regulatory Scrutiny

This article is part of a series on  Action Tracking in business . Read  'Multiple uses for Action Tracking in Business' to learn more

Proving control, not just claiming it

In process safety, you need to do the right thing every time. You also need to be able to demonstrate clearly and consistently that you did them, why you did them, who approved them, and what evidence shows they’re effective.

That’s what an audit trail is for. And when regulators, corporate assurance teams, JV partners, or internal technical authorities start asking questions, traceability is what separates “we think we’re safe” from “we can prove we’re in control.”

The real risk: gaps hidden by weak records

Auditors can get to the point very quickly - expect questions like:

• “Why is this safeguard considered adequate?”
• “Where did this decision come from?”
• “What changed—and who approved it?”
• “How do you know this action is actually complete?”
• “Show me the evidence.”

If  getting the answers means searching emails, spreadsheet versions, or vague memories, you’re relying on goodwill and luck.

What “scrutiny ready” looks like

We're using the term 'Scrutiny' because not everything is a formal audit. Different stakeholders need different data and levels of detail, but we're outlining practices which will allow you to be prepared for whatever demands are made.

It’s about building a defensible chain of evidence from hazard to control to verification, so that a third party can follow the logic without interpretation.

A strong approach has three pillars:

1) Audit trail: the who/what/when

A credible audit trail captures:

• Who created, edited, or approved something
• What changed, and ideally why
• When it happened
• Supporting evidence attached.

That matters because regulators and independent auditors are often evaluating governance, not just technical content.

Read more about how effective action tracking can improve leadership and governance

2) Traceability

Traceability connects:

• Hazard, scenario, or major accident hazard
• Risk assessment outputs such as HAZOP, LOPA, Bowtie, QRA
• Required safeguards or barriers
• Actions and changes including MOC
• Verification and effectiveness evidence
• Ongoing sustainment such as testing, inspections, competency

Without that link, you can complete tasks yet still fail to demonstrate control.

3) Evidence packs: prove it

For safety-critical items, evidence is key. The goal is an evidence bundle appropriate to the action type.

Typical examples include:

• Approved drawings such as P&IDs, cause and effect, layouts; calculations; datasheets
• Test, commissioning, and proof test records such as FAT, SAT, loop checks
• Procedure revisions plus training and competency records
• Inspection findings plus photo or field verification
• MOC approvals and readiness or handback documentation

A practical traceability model you can standardise

Here’s a repeatable way to structure records so you can answer regulator-style questions quickly:

Define the risk context up front

• What hazard scenario does this relate to?
• What is the consequence being controlled?
• What safeguard intent is required?

Create action records that are testable

• Clear deliverable
• Acceptance criteria
• Required evidence types
• Owner, verifier, due date, risk level

Link to the source and to change control

• HAZOP node, deviation, action ID; audit finding; incident recommendation, etc.
• MOC reference where relevant

Capture decision rationale

• Why this solution?
• What alternatives were considered?
• What assumptions does it rely on?

Verify effectiveness, not just completion

• Independent verification appropriate to risk
• Evidence confirms the safeguard intent is achieved in the field

Close with a defensible statement

“Closed because X evidence demonstrates Y safeguard intent, verified by Z on DATE.”

This is exactly the kind of narrative auditors look for.

Common failure modes (and how to prevent them)

“We can’t find the evidence.”

Fix: require evidence attachments at closure, not links to personal drives or inboxes.

“We don’t know who approved the decision.”

Fix: enforce role-based approval steps (for example TA, Process Safety, Operations) and record them automatically.

“Actions drift and lose context.”

Fix: keep the link to the original hazard or finding and safeguard intent so closure decisions remain understandable months later.

“MOC and actions live in separate worlds.”

Fix: cross-link MOC, actions, and risk assessment so the full chain is visible.

“Spreadsheets break under pressure.”

Fix: if the work is high governance (major hazards, multi-site programmes, JV visibility), track it in a system designed for audit trails, access control, and version integrity—not parallel edits and emailed copies.

To learn how the Pisys Action Tracking system addresses these requirements visit our action tracker page

What to measure if you want real assurance

If you want readiness that holds up under scrutiny, track indicators that reflect governance quality:

• Percent of safety-critical actions closed with complete evidence packs
• Overdue high-risk actions and escalation adherence
• Re-open rate after verification
• Average age of open regulatory or assurance actions
• Traceability completeness, meaning actions linked to hazard, barrier, and verification

Summary

Regulatory scrutiny readiness is  an outcome of everyday discipline.

• Audit trail that can’t be disputed
• Traceability that explains why
• Evidence that proves effectiveness
• Governance that shows accountability

When those are built into your process, scrutiny becomes routine. You’re not scrambling to assemble a story—you’re simply showing the one you already have