In process safety, “done” is a dangerous word.
A task can be completed, an email can be sent, a document can be updated, and an action can be marked closed while the real-world risk remains unchanged. That’s how organisations end up with paper safeguards: controls that look great in an action tracker but don’t reliably exist, don’t work as intended, or won’t be sustained.
Verification and evidence-based closeout is how you prevent that. It’s the discipline of proving that a safeguard is not only delivered, but effective.
Completion without proof can be the gap that causes actions to be rejected by reviewers:
Most rejected actions share a common story.
The action was implemented in some form.
The record shows it was closed.
When a reviewer ( or auditor) checks the action, the evidence is thin, the intent is unclear, and confidence collapses.
The fix isn’t more bureaucracy. The fix is a higher-quality closeout standard: risk-based verification, objective evidence, and a clear closure rationale.
What “prove it’s done” actually means
Evidence-based closeout is not about collecting documents for the sake of it. It’s about answering three questions that matter under scrutiny:
- Did we deliver what we said we would deliver?
- Does it achieve the intended safeguard outcome for the hazard scenario?
- Can we demonstrate that to an independent reviewer months or years later?
That last point matters because process safety assurance outlives people, projects, and org charts.
Verification vs validation vs completion
These words get blurred, and that’s where problems start.
- Completion means the task was performed.
- Verification means the deliverable meets the defined requirements.
- Validation means the safeguard works in the real operating context for the intended scenario.
You don’t always need deep validation for every action, but if the consequence is high, you need more than “we did it.”
Best Practice in action closeout
1) Closeout criteria are defined up front
If you don’t define what evidence is required at the start, you will accept weak proof at the end.
Good closeout criteria includes:
- acceptance criteria, what “good” looks like
- minimum evidence types required
- who must verify, and at what level
- what field checks are needed (if any)
2) Actions are written to be testable
Vague actions create vague closure.
A strong action specifies:
- the deliverable
- he scenario or barrier intent it supports
- how it will be checked
- what “done” will look like
3) Evidence is appropriate to the action type
Different safeguards need different proof. “Attach the procedure” is not proof that a procedural safeguard exists in practice.
Typical evidence bundles include
Engineering and design safeguards:
- approved P&IDs, C&E, logic narratives, datasheets
- calculations, sizing checks, set points, design basis
- FAT/SAT records, loop checks, commissioning sheets
- as-built confirmation and field verification records
Instrumented safeguards and alarms
- alarm rationalisation entries and priorities
- set point approvals and change records
- proof test procedures, test results, interval justification
- override/bypass controls and governance records
Mechanical integrity safeguards
- inspection reports and findings closeout
- corrosion monitoring data and trend notes
- fitness-for-service assessments
- work orders showing completion and sign-off
Operational and procedural safeguards
- revised procedures with version control
- training records and competency confirmation
- field observation evidence (line checks, job observations)
- audit sampling showing the behaviour is happening
Organisational and management safeguards
- role assignments and responsibility mapping
- MOC records for org/process changes
- assurance schedules and completed checks
- management review evidence and decisions
4) Verification is independent when risk is high
The higher the consequence, the more important 3rd party review becomes.
Independence can be:
- a technical authority review
- process safety verification
- operations leadership sign-off
- a separate assurance function
The important part is that verification is credible and proportionate to the risk.
5) Closure includes a clear rationale
A strong closeout record is short but defensible.
Closed because the attached evidence demonstrates the safeguard intent is achieved for scenario X, verified by Y on DATE.
That statement forces discipline. It creates a record that can be understood later, and it reduces the likelihood of re-opened actions.
Common failure modes (and how to prevent them)
“We updated the document, so it’s done.”
Fix: require adoption evidence (training, field verification, audit sampling) for procedural and human-dependent safeguards.
“The design is complete, but installation is pending.”
Fix: split the action into stages (design, procure, install, commission, verify) with evidence at each stage.
“Evidence is in someone’s inbox.”
Fix: evidence must be attached to the action record with version control, not scattered across personal storage.
Metrics that tell you whether your closeout standard is working
- Percent of actions closed with complete evidence packs
- Re-open rate after verification or audit
- High-risk actions closed without independent verification
- Average time between “implemented” and “verified”
- Number of rejected actions linked to weak closeout
Bottom line
Process safety action management is a discipline to help deliver risk reduction you can defend.
Verification ensures the deliverable meets requirements.
Validation ensures it works in real conditions.
Evidence-based closeout ensures you can prove it later.
If your organisation adopts a “prove it’s done” standard—defined up front, proportional to risk, and backed by objective evidence, you reduce rejected actions, strengthen audit readiness, and build genuine confidence that safeguards are real.
