HomeMy Public PortalAboutExhibit MSD 70K - Review of the District's Safety Program - November 2022This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program FY 2022 AUDIT PLAN
Metropolitan St. Louis Sewer District
Review of the District’s Safety Program
Fiscal Year 2022
December 2022
Exhibit MSD 70K
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program I FY 2022 AUDIT PLAN
The St. Louis Metropolitan Sewer District
Review of the District’s Safety Program
December 2022
Table of Contents
Introduction and Scope .......................................................................... 1
Objectives .............................................................................................. 3
Methodology ........................................................................................... 4
Overall Conclusion and Results ............................................................. 5
Opportunities for Improvement ............................................................... 6
Acknowledgements .............................................................................. 16
INTRODUCTION AND SCOPE
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 1 FY 2022 AUDIT PLAN
Introduction:
The District employs approximately 910 full-time employees at seventeen (17) District sites,
which include the main office, seven (7) treatment plants, three (3) pump station control
centers, three (3) maintenance yards, and three (3) garages.
Inherently, the areas of greatest risk are contained within the daily tasks performed
by personnel in Operations (approximately 560 employees).
The process to administer the District’s safety program is an effort that is currently directed
by Operations Management but does involve a coordinated effort of District personnel that
includes assistance from the Training and Risk Management Groups, which are a part of the
Human Resource Division. A high-level description of roles is as follows:
• Safety Coordinators (Operations): Perform monitoring, reporting, investigations
(accidents), and some training. Report to Operations Management.
• Training Group (HR): Develop, provide/perform, and track training.
• Insurance and Risk Management (HR): Process/review and track accident
events/claims, including incidents involving workers compensation claims.
See more about the Safety Program structure at the recommendation at Item #2.
Regarding OSHA (Occupational Safety and Health Administration), the District is not
subject to the guidelines, requirements, and the oversight procedures of OSHA. Section
(3)(5) of the Occupational Safety and Health Act of 1970 specifically excludes Federal
OSHA's authority over employees of State and local government entities.
Regarding contractors performing work on behalf of the District, the District has no
responsibility or liability for the safety of the personnel performing the work.
Per the District’s Standard Construction Specifications document that governs the contracts:
“The Contractor shall be solely responsible for the safety of the public and those
engaged or employed during construction until completion of the work.”
The area of Safety was last reviewed by Internal Audit in 2018/2019.
INTRODUCTION AND SCOPE
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 2 FY 2022 AUDIT PLAN
Scope:
The scope of this engagement consisted of a review of the overall procedures for the District’s
Safety Program. Areas of focus included the following:
• Overall safety policies and procedures
• Employee training:
o Performance and completion
o Tracking of training activities
• Daily monitoring of safety procedures
• Enforcement of safety procedures
• Incident/accident analysis (investigation)
• Overall monitoring and reporting of activities
• Overall management of the program
• Employee performance reviews as related to Safety
The scope also included a review of performance data and related metrics.
In addition, the scope included visits and observational activities at the following facilities:
• Bissell Treatment Plant
• Lemay Treatment Plant
• Lower Meramec Plant (Fine Road)
• *Grand Glaize Treatment Plant and Yard
• *Sulphur Yard
• *Mintert Yard
*Visits included traveling to sites in the field and observing District crews performing
tasks in the field.
OBJECTIVES
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and should not be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 3 FY 2022 AUDIT PLAN
Objectives:
The overall objectives of this engagement were to ensure that:
• The District’s policies and procedures are adequately designed (best practices) and
documented (specifics are addressed – limit ambiguity).
• The District’s program to train employees is adequately designed and implemented:
o Required training per job classifications corresponds with job duties.
Training requirements are adequately documented.
o Performed/completed training is documented.
o Training activities are tracked and monitored.
Missing/uncompleted training is identified and addressed in a timely
manner.
Personnel is held accountable for missing/uncompleted training
• District’s efforts to physically monitor compliance with prescribed safety protocol are
effectively designed and performed.
o Monitoring coverage is adequate.
o Areas of higher risk are the focus.
• Physically at District facilities and in the field District employees utilize appropriate safety
protocol (best practices) when performing the tasks required as part of their job duties.
o Personnel are held accountable for not following prescribed safety protocol.
• EMR (Experience Modification Rate) metrics are reasonable. (near 1.0)
o Other related metrics and performance data are reasonable.
• Incident/accident investigations are performed in a thorough and timely manner.
o Investigation results are adequately documented.
METHODOLOGY
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and should not be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 4 FY 2022 AUDIT PLAN
Methodology:
To accomplish the above objectives, Internal Audit (IA):
- Obtained the District’s “Health and Safety Compliance Policy and Procedures Manual”.
o Reviewed to gain an understanding of the procedures utilized by the District.
o Reviewed content for adequacy.
- Held discussions and performed walkthrough procedures to gain an understanding of the
procedures and processes utilized for:
o The safety training program including procedures for:
Determining and documenting the training requirements for each job
classification.
Performing and documenting the completion of training.
Monitoring and tracking training progress.
Identifying missing/uncompleted training.
• Ensuring completion.
Holding personnel accountable for uncompleted
training.
o Monitoring and observing District personnel as they perform their job duties.
Ensuring safety protocol is followed.
Ensuring District facilities are safe.
o Investigating and analyzing safety-related incidents (accidents).
Holding personnel accountable for violations of safety protocol.
o Performing performance reviews.
Holding personnel accountable for violations of safety protocol.
Performed facility/site visits on six different occasions. Observed personnel perform
various job-related tasks and inspected District facilities. Focused on compliance with
required safety protocol. Documented results of physical observations and reviews.
- Performed detail testing of the following areas:
o Training
o Investigations of safety-related incidents
o Employee performance reviews
Reviewed and analyzed performance data/metrics (costs, EMR).
OVERALL CONCLUSION AND RESULTS
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and should not be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 5 FY 2022 AUDIT PLAN
In the opinion of Internal Audit, the combination of the conditions identified at items one
through three prevent the issuance of a “clean” opinion and result in the issuance of a
Generally Satisfactory opinion. The items are considered to be significant in regard to the
area of Safety when aggregated together. In all, four identified conditions are discussed in
detail in the Opportunities for Improvement section of this report.
Initial Inherent Business Process Risk: High Risk #
Overall Assessment of Engagement Results: Generally
Satisfactory **
____________________________________________________
DEFINITIONS
How Results Are Assessed
** Engagement results are evaluated as Satisfactory, Generally Satisfactory or Unsatisfactory.
• Satisfactory (clean opinion) – No significant engagement findings2 or material
weaknesses3 were noted. Engagement findings1 may have been noted.
• Generally Satisfactory (qualified opinion, i.e., “except for”) – Results contain
significant engagement findings2. No material weaknesses3 were noted.
• Unsatisfactory (adverse opinion, immediate Management attention required) –
Significant engagement findings2 and/or material weaknesses3 were noted.
Types of Findings
1. Engagement Finding (#Low Risk): An engagement finding is a condition that could adversely affect the
organization but is less severe than a significant engagement finding or significant deficiency. Classification includes
process or control deficiencies that are not significant deficiencies as well as includes other low risk or low impact
conditions.
2. Significant Engagement Finding (# Moderate to High Risk): A significant engagement finding is a condition that
could adversely affect the organization. Definition includes all types of findings, such as irregularities, waste,
ineffectiveness, conflicts of interest, illegal acts, errors, and significant deficiencies in internal control over financial
reporting as well as other significant internal control weaknesses. A significant deficiency is defined as a deficiency,
or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough
to merit attention by those charged with governance.
3. Material Weakness (# High Risk): A material weakness is a deficiency, or a combination of deficiencies, in internal
control, such that there is a reasonable possibility that a material misstatement of the financial statements will not be
prevented or detected and corrected in a timely basis. For internal audit purposes, the definition also includes
material and/or severe irregularities, waste, ineffectiveness, conflicts of interest, illegal acts, errors, and other material
control weaknesses, etc.
(The term “material weakness” should be thought of as a serious category of significant engagement findings and/or
significant deficiencies. However, not all significant engagement findings and significant deficiencies are material
weaknesses.)
^ - Definitions are based on guidance from the IIA Standards, GAAS, and the PCAOB.
# - Risk is assessed at the District (Entity) Level. (Risk to the District as a whole)
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 6 FY 2022 AUDIT PLAN
1. EMR (Experience Modification Rate) and Site Visits
EMR Overview:
Basic definition of EMR (Experience Modification Rate): A numeric representation of an
entity’s workers compensation claims history and safety record as compared to other entities
within the same industries (*job classification codes), within the same state. The rate basically
states one of three things:
I. This entity is riskier than average (EMR > 1.0). MSD – SEE BELOW
II. This entity is no more or no less risky than average (EMR = 1.0).
III. This entity is safer than average (EMR < 1.0)
The rates are calculated by the National Council on Compensation Insurance (NCCI) based on
data provided by the entity and the entity’s insurance company.
A desirable EMR level is around 1.0. An EMR below 1.0 is the most desirable.
*Class codes are: 6306 - Sewer Construction – All Operations; 7580 – Sewage Disposal Plant Operations; 8810 –
Clerical Office; 9402 Sewer Cleaning
Condition - EMR:
The District’s EMR numbers (Experience Modification Rate) are not at a desirable level. The
rates are in the “riskier than average” category. For the past ten (10) years, EMR activity is
as follows:
Year
Years Reflected
in the
Calculation
A. Actual Losses
- *Per NCCI
Calculations
B. Expected
Losses - *Per
NCCI
Calculations
EMR C. Excess of Actual
over Expected
2013 2009, 2010, 2011 2,661,345 2,601,355 1.02 59,990.00
2014 2010, 2011, 2012 2,775,180 2,557,340 1.09 217,840.00
2015 2011, 2012, 2013 2,785,237 2,638,217 1.06 147,020.00
2016 2012, 2013, 2014 3,020,730 2,760,833 1.09 259,897.00
2017 2013, 2014, 2015 3,318,068 2,771,743 1.20 546,325.00
2018 2014, 2015, 2016 3,999,042 2,897,925 1.38 1,101,117.00
2019 2015, 2016, 2017 4,780,785 2,901,345 1.65 1,879,440.00
2020 2016, 2017, 2018 5,560,652 3,054,150 1.82 2,506,502.00
2021 2017, 2018, 2019 5,578,034 3,290,478 1.70 2,287,556.00
2022 2018, 2019, 2020 4,705,992 3,148,109 1.49 1,557,883.00
*Per NCCI Calculations (NCCI formulas are lengthy and complicated – IA has more
information on the NCCI formulas.)
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 7 FY 2022 AUDIT PLAN
1. EMR (Experience Modification Rate) and Site Visits (Cont’d)
From a review of the District’s EMR rate history going back to 2003, it was noted that the rates
for 2017 through 2022 are the six highest rates for that twenty (20) year period. Now – IA
did know about 2017 - 2019 at the time of the previous audit in 2019 (was included in said
audit). Since 2019, some improvement HAS been made in the District’s EMR. HOWEVER –
The District’s rates are still not at a desirable level. Significant improvement is still
needed.
The contrast between earlier and most recent years can be seen below:
• 2003 through 2016 (14-year period): average rate was 1.09 (high: 1.17; low: 1.00)
• 2017 through 2022 (6-year period): average rate was 1.56 (high: 1.82: low: 1.20)
o Worker’s compensation costs (net of recoveries) and number of incidents by calendar
year are as follows (13-year span – covers the 10 years of EMR reporting):
YEAR COSTS INCURRED # of INCIDENTS AVG. COST
2009 $711,053 123 $5,781
2010 $1,209,215 119 $10,161
2011 $734,596 99 $7,420
2012 $795,508 111 $7,167
2013 $1,085,294 150 $7,235
2014 $994,690 154 $6,459
2015 $1,892,840 127 $14,904
2016 $1,874,775 153 $12,253
2017 $2,660,838 136 $19,565
2018 $2,176,613 118 $18,446
2019 $1,980,765 132 $15,006
2020 $980,750 83 $11,816
2021 $1,466,414 100 $14,664
To provide a clearer picture of the numbers, IA performed an analysis of the most recent EMR
and the underlying numbers and determined the following:
• The most recently published EMR is 1.49 (SEE PREVIOUS PAGE).
o The associated District underlying worker’s compensation costs for the 1.49
EMR, before any applied NCCI adjustments factors, are $5,138,128.
2018: $2,176,613
2019: $1,980,765
2020: $980,750
To achieve an EMR of 1.0 the District would have needed to lower the WC costs by
approximately $2.328 million (45%) over the three-year period. (calculated estimate).
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 8 FY 2022 AUDIT PLAN
1. EMR (Experience Modification Rate) and Site Visits (Cont’d)
The costs incurred for the years 2013 through 2021 total approximately $15.2 million (from
table on previous page). The top five types of injury classifications (by dollars) are listed
below:
Type Injury Total Dollars
(approximate)
# of
Incidents
Percentage of
Total Dollars
Strain or Injury by $7,534,000 433 50%
Fall, Slip, or Trip $4,239,000 261 28%
Struck or Injured by $899,000 130 6%
Motor Vehicle $528,000 41 3%
Caught In, Under, Between $496,000 42 3%
TOTAL
$13,696,000
907
90%
$13.4 million (or 88%) of the $15.2 million in costs can be attributed to the following sites (in
no particular order):
• Lemay Treatment and Pump
• Bissell Treatment and Pump
• Mintert Yard and Garage
• Sulphur Yard and Garage
• Grand Glaize Treatment, Yard, and Garage
Regarding the above sites, this is what IA expected to see. They are the (largest) Operations
sites with the most activity.
Condition – Site Visits:
When visiting operational work sites and locations, IA noted instances of the following:
a. Excavation – no fall protection (around the trench/work area)
b. Excavation – no means of egress (no ladder in hole/trench)
c. Not wearing vests around heavy equipment/roadway
Effects:
All the conditions described above result in:
• Higher costs to the District:
a. Worker’s Comp
i. Medical
ii. Indemnity
b. Second Injury Fund Contributions
c. Indirect costs (Admin)
• An overall work environment that may not adequately protect employees from injury.
• Disruptions to operations.
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 9 FY 2022 AUDIT PLAN
1. EMR (Experience Modification Rate) and Site Visits (Cont’d)
Recommendation:
The recommendations for this item are contained in the subsequent items described in the
remaining pages of this report. That is, if the District addresses items two (2) through four (4),
IA believes the conditions identified in this item, above, should improve.
Risk Rating at District (Entity) Level: Moderate
Risk Rating at Business Process Level: High
Process Owner Response: See responses at items two through four.
Date of Implementation: See responses at items two through four.
.
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 10 FY 2022 AUDIT PLAN
2. Safety Coordinators/Safety Program Organizational Structure
Regarding this engagement:
• Initially, the area of Safety was under the supervision of the Human Resources
Department.
• Initially, there were three (3) Safety Coordinators, which is not enough Coordinators to
adequately address the safety needs of the District.
• Early into the engagement one of the Coordinators left the District, further weakening the
program.
o Since that time (basically most of 2022), the District has been operating with two
(2) Coordinators.
• Later into the engagement, the area of Safety was moved under the supervision of the
Operations department.
o At this point, the structure of the District‘s Safety Program is somewhat “in flux”.
Recommendation:
With the Safety Program existing in its’ current state, now is the perfect opportunity to revamp
the structure of the District’s Safety Program. With that objective in mind, IA recommends the
following:
1. Step one: absolutely need to hire more Coordinators to make this program effective.
o IA recommends Management establish a team of five (5) individuals.
Should include one Manager.
• All five (5) individuals need to have safety backgrounds and
credentials.
• The manager would supervise but would also work at the
locations and sites performing coordinator-type duties.
2. Develop a more defined structure or system for the coordinators to operate under.
o Improve and standardize checklists and guidance materials used by
coordinators.
3. Once the team is established and “up and running”, begin to take a more risk-based
approach and focus energies on the locations and/or projects with the most risk.
o Have the Coordinator team focus more on working with and assisting employees
out in the field in real-time as safety challenges arise.
4. Make a concerted effort to communicate Management’s priority of “safety first” to the
District’s employees. There is a perception by some employees that safety is not a
priority of Management. That perception needs to be changed (see Issue #3 also).
Note: Operations has been working on the items above. Labor market and/or lack of
available qualified candidates has greatly impeded the process.
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 11 FY 2022 AUDIT PLAN
2. Safety Coordinators/Organizational Structure (Cont’d)
Risk Rating at District (Entity) Level: Moderate
Risk Rating at Business Process Level: High
Process Owner Response:
Ops: Management agrees. Currently working to fill 3 vacant Safety Coordinator positions.
Staffing to an overall level of 5 Coordinators will enable management to address other items
noted.
Date of Implementation: next 12 months
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 12 FY 2022 AUDIT PLAN
3. Training
As part of the procedures for this engagement, IA tested the safety training for District
Operations personnel.
The objective of the testing was to ensure that personnel is completing the
required safety training in a timely manner.
IA tested the training activity for 2020/2021 for fourteen (14) employees from the Operations
Department. Based on that testing, IA noted the following:
o Only one (1) of the fourteen (14) employees had completed all required
training. See the table below for the overall results of the testing
EMP Completed Courses
Late
Courses DNC
(Did not Complete)
1. 9 Late 4 DNC
2. 7 Late -------
3. 4 Late 5 DNC
4. 4 Late 5 DNC
5. ------- 2 DNC
6. ------- 1 DNC
7. ------- 4 DNC
8. 4 Late 4 DNC
9. ------- 2 DNC
10. ------- 1 DNC
11. ------- 3 DNC
12. ------- 1 DNC
13. ALL COMPLETED
14. 4 Late 2 DNC
Recommendation:
To address this condition, IA recommends that Management:
1. Continue steps to improve the communications regarding required training:
• Ensure employees are aware of their required training curriculum.
• Issue reminders of any “missing” training.
2. Continue efforts to provide more opportunities to complete required training:
• Online training
• Live/”classroom” training
As more Coordinators are hired (see Issue #2), the District should be
able to create more opportunities to complete live training. – This issue
appears to be partially a result of the shortage of Safety
Coordinators and COVID.
3. Address missing training through the performance review process (see Issue #4.)
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 13 FY 2022 AUDIT PLAN
3. Training (Cont’d)
4. Make a concerted effort to communicate Management’s priority of “safety first” to the
District’s employees. There is a perception by some employees that safety is not a
priority of Management. That perception needs to be changed (see Issue #2
also).
Risk Rating at District (Entity) Level: Moderate
Risk Rating at Business Process Level: High
Process Owner Response:
Ops: Management agrees and will address by completely staffing the Safety Coordinator
position and revising the Safety Program.
HR is addressing as well. See below.
Note: During 2020/2021 time period both external vendor training and internal
classroom training were affected due to COVID. Group gathering was prohibited, and
online learning was only recommended. This caused learners to miss certain required
safety training especially with our vendor training.
Since external vendor training and classroom training is now being made available. We
are working directly with yard, pump and treatment plant managers/supervisors to
schedule those required safety trainings. We currently have a number of safety trainings
scheduled in the upcoming months.
Training team has been meeting with Safety and managers/supervisors. A needs
analysis has been conducted and an outline of required learning has been identified for
Operations’ employees. HR Training is currently utilizing a tracking software and the
Learning Management System to help us to know when certain training should be
offered.
Usually, a group of required courses have multiple notifications reminders closer to the
deadline for the training. We can make the adjustment and also add additional reminder
in the middle of the deadline. Training notifications are sent to all
directors/managers/supervisors and employees about required training. This
communication is delivered via email. Managers/supervisors and the HR Training team
can run reports within the LMS to check the status of all required training.
Date of Implementation: FY23/FY24
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 14 FY 2022 AUDIT PLAN
4. Performance Reviews
I. IA identified the ten (10) employees with the highest WC expenses incurred during
the calendar years 2020 and 2021. IA noted the following regarding the incidents and
the related costs.
• The ten (10) employees had a total of fifteen (15) incidents during those two
years.
• The total WC expenses incurred for the ten (10) employees were approximately
$970,000 (or $97,000 per employee).
• One employee had three (3) incidents in eighteen (18) months.
• Another employee had two (2) incidents in six (6) months.
• Of the fifteen incidents, five (5) were determined to be preventable by
investigators.
o The other ten (10) we do not know if preventable– preventability
analyses were not documented/not performed (result of condition at
item #2).
II. IA then reviewed the performance reviews for the ten (10) employees identified above.
In reviewing the performance review documentation, IA noted the following:
• Each of the employees received a rating of “Proficient” in the Safety
Competency section of the performance review document.
That is, none of the employees received a “Needs Improvement” or an
“Unsatisfactory” rating in the area of safety.
That does not seem reasonable. Especially with the fact that we
do know that five (5) of the incidents were deemed preventable
(with the other ten being undetermined/undocumented as to
preventability).
IA noted similar conditions in the 2018/2019 engagement. It does
not appear that this specific area has seen much improvement
since the last engagement.
• The cause of this condition is it not completely clear. That is:
When performing performance reviews, are the reviewers not receiving
or afforded adequate access to the appropriate
documentation/information regarding safety/WC incidents???
Or, are the reviewers not properly applying the information available to
them when performing the review process??
It appears to IA that it is a combination of the two
items mentioned above.
OPPORTUNITIES FOR IMPROVEMENT
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 15 FY 2022 AUDIT PLAN
4. Performance Reviews (Cont’d)
Recommendation:
To hold employees more accountable and to assist in the efforts to communicate a more
effective “tone from the top” message regarding the importance of safety, IA
recommends:
• Procedures be developed and implemented that ensure each (Operations)
employee’s safety and accident records are made a mandatory part of the
performance review process.
• Including training records as part of the review process. If an employee is
not up-to-date or current in regard to required training, this should be
addressed during the performance review process (see Issue #3 also).
• Refining/developing guidance for performing (Operations) employee
performance reviews.
Meet and discuss with (Operations) supervisory personnel.
Risk Rating at District (Entity) Level: Low
Risk Rating at Business Process Level: Moderate
Process Owner Response:
Ops: Management agrees and has already addressed with supervision. Currently reviewing
compliance and reporting to ensure accuracy.
HR: With the Oracle Cloud implementation, the Talent Development team and the HR Team as
a whole is working on building training materials and programs for MSD as a whole. Part of this
development is leadership development training and performance coaching and training –
SBOP Strategy 6 Objectives 1 & 2.
Our pervious leadership training was mostly focused for managers and supervisors, currently
our improvements, include team leaders, supervisors, managers and directors, and areas of
development will be performance management (documentation, consistency, policy review,
accountability and communication), payroll (timecards absence management), and benefits.
Previous leadership training was coordinated and delivered by one individual, our improved
leadership training will be delivered by multiple SME’s from different division in HR and other
departments.
In the leadership training, supervisors will be trained on accountability, consistency and
utilization of proper documentation to effectively address performance issues with their
employees.
Date of Implementation: FY23/FY24
ACKNOWLEDGEMENTS
This report is intended solely for the use of The Metropolitan St. Louis Sewer District (“MSD”) and is not intended to be and should not
be used by any other parties without the prior written consent of MSD.
Review of the District’s Safety Program 16 FY 2022 AUDIT PLAN
Internal Audit Engagement Team:
MSD Internal Audit:
Todd Loretta
Armanino:
Henry Woods
Bret Simmons
Anthony Odarczenko
Chrisy Pedroli
We would like to thank District personnel for their excellent cooperation and assistance during
this engagement.
Specifically, we would like to express our gratitude to the following:
HR
Tracey Coleman
Dino Kiveric
Belinda Farrington
Lakesha Prince
Jennifer Miller-Bell
Operations:
Bret Berthold
Brian McGownd
Debbie Aylsworth
Joey Lech (formerly part of HR)
Sean Prudence (formerly part of HR)