Planning for a PSM Compliance Audit

When was your last process safety compliance audit? If you are subject to the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) of Highly Hazardous Chemicals standard (29 CFR 1910.119), you’re required to conduct a program compliance audit every 3 years. If you’re due—or if you can’t remember when you conducted your last compliance audit—here’s a review of what you must get done.

Remember that the purpose of the audit is to gather facts and information that will verify and demonstrate your facility’s compliance with the OSHA standard. The audit includes an evaluation of the design and effectiveness of the PSM system and a field inspection of the safety and health conditions and practices to verify that your system has been (and continues to be) effectively implemented.

Planning the Audit

You should have your two most recent compliance audits readily available to review. That will tell you what processes were reviewed in the past, who conducted the review, and whether any identified issues were dealt with.

Your new audit needs to review enough processes to give you confidence that your program is, in fact, compliant—although, if you have a lot of covered processes, it doesn’t necessarily have to include all of them. Choose which processes to audit based on what has been audited in the past (you may wish to audit different processes this time around), or based on the processes where you think an audit may do the most good—by, of course, identifying the most problems. It may sound counter intuitive, but if you fix the worst of your problem areas, you should be able to feel better about what remains.

Your previous audit documents can also give you a basis for establishing the format, staffing, scheduling, and verification methods you’ll use.

The format should be designed to provide the lead auditor with a procedure or checklist that details the requirements of each section of the standard.  The names of the audit team members should be listed as part of the format as well. The checklist, if properly designed, could serve as the verification sheet that provides the auditor with the necessary information to expedite the review of the program and ensure that all requirements of the standard are met. This verification sheet format could also identify those elements that will require an evaluation or a response to correct deficiencies. This sheet also could be used for developing the follow-up and documentation requirements.

Choosing Audit Team Members

Choose your audit team members with an eye to their relevant experience, knowledge, and training. They should be familiar with the processes and also with auditing techniques, practices, and procedures.

The size of the team will vary depending on the size and complexity of the process under consideration. If your plant or process is small, you may need only one knowledgeable person to conduct the audit. For a large, complex, highly instrumented plant, you may wish to have team members with expertise in a variety of areas, including:

  • Process engineering and design
  • Process chemistry
  • Instrumentation and computer controls
  • Electrical hazards and classifications
  • Safety and health disciplines
  • Maintenance
  • Emergency preparedness
  • Warehousing or shipping
  • Process safety auditing

Tomorrow we’ll look at the actual audit process.