You make a good point - at this moment, there is a grey area on this topic which is not good news should there be a incident. Fingers will be pointed back and forth.
After talking to KAM to get some more background, the important points re. what, how, who, when …are as follows:
*KNT takes out an insurance policy related to the whole KNT area, this includes activities by real estate customers, both on TASC and EDC. A yearly audit is mandatory as per the terms of this policy.
*The responsibility of following the guidelines in the insurance policy is with the person signing the policy – KNT - so KNT is the party that sets up the audits.
*The mandatory frequency is yearly but there is nothing stopping us from increasing this to at least twice per year (or more if initial result are very negative).
*The people involved in the audit on our side should be a TD rep and a SHE(Q) rep + the KAM to handle all coordination with customer pre- and post –audit, and a customer rep on their side.
For your question, I think the sweet spot between ensuring safety and not bothering the customer is an audit 2 x per year. with a post-inspection each time to confirm corrective action has been taken.
Are there any dates planned this year already that you know of? I will ask the same question to KAM. Depending on the answer we can set up a plan with fixed dates for each customer in 2015.
Rgds