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Many of these shortcomings relate to the legal requirement under LOLER to subject all lifting equipment to regular ‘thorough examination’. Broadly speaking, this is designed to determine whether equipment is fit for the coming period of service. However, while there are still organisations that fail to grasp the basics, the key problem often lies not so much in a failure to implement a proper programme of thorough examinations but in placing too great a reliance on such procedures to ensure the continuing safety and integrity of lifting devices. Anyone with a degree of familiarity with the legislation and its supporting codes of practice should recognise both what constitutes a thorough examination and when one should be undertaken. As a starting point, it is worth clarifying what equipment is actually involved. Under LOLER, lifting equipment includes any equipment that is used at work for lifting or lowering loads, including attachments used for anchoring, fixing, or supporting it. In practice, this means an extremely wide array of lifting equipment and accessories, routinely used in areas as diverse as manufacturing, construction, distribution, and the offshore sector. It is also worth stressing that it is often the most simple and economic items, such as slings and lifting attachments, which play the most safety-critical roles. They are also typically the most vulnerable to damage, so when it comes to ensuring that lifting equipment is fit for purpose, it is important that nothing is overlooked. As for what constitutes a thorough examination, the Code of Practice for the Safe Use of Lifting Equipment (CoPSULE)1 defines it as a “visual examination, carried out by a competent person carefully and critically and, where appropriate, supplemented by other means, such as measurement and testing, in order to check whether the equipment is safe to use”. Under previous legislation, thorough examination did not encompass any testing of the equipment. But LOLER encompass procedures such as proof-load, non-destructive, light-load, and operational testing. Lifting equipment should be subjected to a thorough examination before it is put into service for the first time. However, LOLER offer an exemption, provided that: the equipment has not been used before; and, in cases where an EC declaration of conformity is required, the employer has received such a declaration not more than 12 months before the equipment is put into service.2 For any equipment that has to be installed, such as an overhead travelling crane, a thorough examination is necessary to ensure that it has been carried out correctly and is safe to operate. Reflecting a more flexible and risk-based doctrine, LOLER offer employers two options for establishing the frequency of thorough examinations. The first and most common option is for examinations to take place at maximum fixed intervals: six months for equipment that is used for lifting people and accessories; and 12 months for other lifting equipment. Alternatively, a LOLER competent person can draw up an examination scheme, where intervals are based on the frequency and nature of use, the operating environment, and the rate at which a particular piece of equipment will deteriorate.


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Modernize the standards so they are relevant and compatible with the innovations taking place in the profession. For example, where an element in the old standard referred to the “human resources” element of the system of quality control, the new standard refers to a resources element that includes human, intellectual, and technological components. The requirement to document and test all processes, process risk points, and controls is where the quality management standards most resemble the rules for implementing SOX 404(b). The processes are all in place, Peo said, but documenting and testing them is a different challenge. “Some people thought the same thing about SOX 404 when they first implemented,” Peo said. “It was like, ‘How hard can that be?’ They already have the processes in place. And you pretty quickly realized, it’s a different exercise when you have to go through and document it all and then test it.” “My first piece of advice,” Haskell said, “would be to figure out where you are in relation to the new standard, figure out the quality objectives in the new standard, and line them up against what you’re measuring today as part of your system of quality control.” Experts say it’s critically important that the standards can be easily applied to audits of all levels of complexity at all the various sizes of firms. “There could be different challenges for different sets of firms, depending on how the standards are written,” said Brian Croteau, CPA, a partner in the National Quality Organization of PwC’s Assurance Practice and Regulatory Risk and Quality Control leader. “But the good news is that it seems the standard setters and regulators are focused on that issue and really are trying to think about how to write click here to investigate the standards, or in the IAASB’s case, already wrote the standard, in a way that they believe is sufficiently scalable to firms of all sizes.” Nonetheless, firms of different sizes will have different challenges with implementation. Smaller firms may struggle with this effort because they don’t possess the resources that larger firms can rely on for implementation. On the other hand, processes and controls at small firms that perform less-complex audits won’t be as complicated, so they will be easier to document. “When you have a huge firm, things can get pretty complicated just from a process standpoint because there are so many people and so many different types of audits,” Peo said. “I think smaller firms will have a challenge, but I think they’re probably just different challenges from larger firms.” Although implementation may be burdensome, experts say it’s worth it because they believe the standards ultimately will result in better performance on audits. “A strong system of quality control provides the framework for consistent execution of high-quality audits at the engagement level,” said Christine Davine, CPA, national managing partner for quality, risk, and regulatory for Deloitte & Touche LLP. “That framework then positions our engagement teams for success on their audits.” The standards add to a groundswell of support in the profession for improving the training, tools, and processes that lead to improved performance on audits. It has been almost seven years since the AICPA embarked on its Enhancing Audit Quality initiative, which has provided resources and guidance for firms and practitioners to use in their pursuit of continuous improvement. There may be challenging times ahead for auditors as they change their systems to reflect a risk-based approach and document processes and controls. But even if the implementation effort reminds auditors of SOX 404(b), there is a real opportunity ahead with the quality management standards. It would be possible for firm leaders to treat adoption like a compliance requirement, dutifully checking the boxes and documenting the controls to get the work completed so they can report that they are in compliance.