In order to meet the audit requirements, a company has to be audited at peak season or when they are operating at at-least 70% capacity.  It is expected, at this time, that the majority of the safety records have been generated and retained, such as pre-planning meetings, hazard identification, worker orientation and training, site safety inspections, equipment maintenance and inspections, and Emergency Response Procedures (ERP).

The purpose of the 3 month documentation requirement is to ensure that safety policies, procedures, and records demonstrate effective and consistent implementation of the safety program.  The 3 month documentation requirement applies to the entire safety program, not just records concerning peak season activities.  Therefore, the 3 month documentation can begin before the peak season followed by the audit during the peak season.  Documentation may include safety program policies, procedures and records. Below are ways that documentation could be accumulated:

• For seasonal operations it is expected that the company's safety program will be developed and implemented in advance of the seasonal activities.
• New companies or companies that have just developed a safety program should start accumulating records as soon as possible.  Such records may include safety meetings, inspection records (office, equipment storage), training records (training plan, first aid training, ERP training for current employees), pre-job planning and hazard identification, contractor selection and evaluation, etc.
• For existing companies certain safety records mentioned above may already exist from previous months or last year.  The external auditor or person preparing the SEBASE audit report submission should recognize that the existing records support that certain elements of the safety program have been implemented.  Additional safety program policies and procedures may have been developed to further enhance the program to achieve SAFE certification.  The necessary records (e.g. training and inspection records) to demonstrate the improved safety management measures will be accumulated over time when work activities take place or as directed by the safety policies such as incident investigation.

It should be clarified that the Council is not expecting 3 months of records on each program element.  For example in the SEBASE audit questions C4 and C5; ERP (Emergency Response Procedures) for the existing office may have been established over 3 months ago; however, the ERP for specific operation sites are developed just prior to the start of site activities and vary from site to site.  Another example is SEBASE audit question F2 - "Are all reported incidents investigated?”  If the company has had no incidents there should still be documentation (reporting policy & investigation procedures) to support that if an incident were to occur the company would carry out the appropriate actions and that the employees are aware of the policy.