Does Your PSM Auditor Have the Right Stuff?

Every 3 years, you need to complete an audit of your process safety management (PSM) processes. Often, the emphasis is on the standard and the facility—but in order to conduct a thorough and effective compliance audit, you also need a skilled auditor. And that means more than someone who knows what the standard says.

If you wanted a financial audit, there would be no shortage of third parties who could tell you exactly what to look for in a qualified auditor. That kind of information is a little more difficult to find for PSM auditors. The PSM standard simply requires that the audit be conducted by “at least one person knowledgeable in the process.” That’s not a lot to go on.

Many different organizations have created competency frameworks for auditors—but these are often specific to financial auditing or other types of auditing that are very dissimilar to PSM auditing. Fortunately, the Institute of Internal Auditors has created a competency framework for EHS auditors that could be especially useful to employers who are planning their next PSM compliance audit. While this framework is on the older side, much of the information within it is evergreen for EHS managers, and it suggests general competencies, functional competencies, and technical competencies that make for a skillful EHS—and, by extension, PSM—auditor.

General Skills

Whether auditing your balance sheet or your maintenance procedures, your auditor will do a better job if he or she has mastered some basic auditing skills that include:

• Professional ethics. Your auditor must understand and adhere to established professional codes of ethics, which require fundamental integrity, objectivity, and confidentiality.
• Objectivity. An auditor should avoid conflicts of interest and cultivate an unbiased and impartial approach to evaluations.
• Reasoning and analytical skills. Strong reasoning skills enable auditors to use information gathered during an audit to make sound decisions in a timely manner and to develop appropriate recommendations and possible alternative solutions to problems.
• Interpersonal skills. Because auditors must be able to gather accurate information from many different people, they must have strong interpersonal skills and be able to work well as part of a team.
• Communication skills. Interpersonal skills are one vital area of communication skills, but it is also important for auditors to have strong writing and presentation skills.
• Diligence. An auditor should not make decisions based on incomplete data when better information is readily available.
• Flexibility. An inflexible approach cannot account for changing circumstances, so auditors need to be adaptable.
• Intuition. Although auditors should make every reasonable effort to obtain the information needed for decision making, they may also need to make judgement calls in the absence of complete information, based on their experience and observations.

Functional Competencies

In addition to broadly applicable ethics and reasoning skills, there are some more specific skill sets a good auditor should have, including:

• Information technology skills. A lot of information needed to assess compliance with PSM and other regulations is found in databases and electronic systems; an auditor should be able to use these, as well as using other information technology to generate recommendations and reports and complete other audit tasks.
• Interview skills. A more specific skill set than the general “interpersonal skills” mentioned above, auditors need to be able to obtain relevant information from interviews and evaluate that information for accuracy.
• Mentoring skills. A good lead auditor needs to be able to pass along their skills to others and provide feedback to other members of the audit team.
• Conflict resolution skills. Another specific subset of “interpersonal skills,” conflict resolution is an essential skill for anyone in a leadership position. PSM auditors must sometimes deliver bad news or get different departments to work together to solve problems—all of which is easier with strong conflict resolution skills.
• Powers of observation. These aren’t “superpowers,” in the sense of something supernatural, but rather a skill that comes from practice, and that enables an auditor to compare the situation in the facility to what the records say, and to what the standards require.
• Supervision. A PSM audit is seldom a one-person job, so auditors need to be able to effectively assign and oversee a team effort.
• Writing skills. Auditors must be able to prepare written reports that clearly summarize issues, evidence, and alternatives.
• Time management. Setting goals, establishing priorities, and completing audits in a timely manner are essential to a successful audit.
• Documentation. In order to demonstrate compliance—or noncompliance—an auditor must clearly document the audit process and findings.
• Legal protections. Auditors must be able to identify and protect sensitive information that is used or uncovered during an audit.

Technical Competencies

The Institute of Internal Auditors divides EHS technical competencies into generally-applicable skills and skills that apply to specific assignments. Their recommended generally-applicable technical competencies include:

• Internal management controls. This is an organization-specific skill set that an auditor needs in order to make sure that the information needed to detect and prevent compliance issues is up to date and accurate.
• Statistics and probability. Basic statistics and probability knowledge is essential for determining how many samples are needed to provide a representative sample and to understand the various qualitative limits that apply to EHS issues in the workplace.
• Risk assessment. Process safety management is not just about regulatory compliance; it is also about risk management, and risk management begins with risk assessment. Auditors need to have a solid grasp of risk assessment terms and procedures.
• Regulatory knowledge. In any EHS area, and in PSM especially, it is vital for an auditor to have a broad knowledge of the applicable regulations and how they apply to the workplace.
• Sustainability and corporate social responsibility. An EHS auditor must understand how EHS activities fit into broader corporate goals, and PSM is just one of the many regulations that can have an impact on risk and long-term sustainability.

Some types of audits require even more specific skills. An auditor conducting a PSM audit will benefit from careful study and application of:

• Chemical hazards. The effective management of highly hazardous chemicals regulated under the process safety standard demands knowledge of the chemicals in a covered process and their hazards.
• Health and safety knowledge. In order to evaluate the safety of a covered process, some knowledge of the technical principles of the process is required.
• Process operations. An overall understanding of the processes in the workplace, particularly the covered processes, is needed in order to conduct a risk assessment.

Yes, it’s a lot to consider—but PSM management and auditing should never be taken lightly. With the right person at the helm, you rest easier with the confidence that your organization’s PSM processes and overall EHS compliance efforts will be successful.