A process safety audit serves to insure that the owner and operator of a process plant can meet or exceed the requirements of OSHA and the EPA. Process Technical Services (PTS) personnel understand OSHA's Process Safety Management standard (29 CFR 1910.119) and the EPA's Risk Management Program Regulation Title 40 Part 68. Most have served as a PSM implementation team member for at least one year before becoming a PSM/RMP auditor.
The experienced auditor covers every aspect of auditing from gathering data via records and interviews, keeping notes, writing reports, and making recommendations. They have applied all the rules and methods to audit actual PSM practices on a process operation.
Auditing for process safety and risk management is the key to measuring how effective plant management is in performing these functions. Process safety begins with personnel safety. A program that stresses personnel safety automatically includes safe and responsible operation of the process facilities. Many serious process accidents that have resulted in a serious loss of production and cost many millions of dollars to recover can be traced to a failure to establish and properly manage a personnel safety program.
Safety audits require that the auditor understand auditing fundamentals in order to properly structure effective PSM/RMP audits. Every plant and every operating organization will have certain similarities, but will also have unique characteristics. The “one shoe fits all” rules cannot be applied to PSM/RMP audits. Each one must be designed for a particular installation. How to apply PSM and RMP compliance auditing to a particular system requires knowledgeable and experienced personnel.
Safety audits should be designed to have a dual purpose: verifying compliance with regulations and identifying weaknesses in the design and implementation of PSM/RMP programs. It is only through the discovery of program weaknesses can improvements be made. At times these discoveries will mean only an incremental improvement. At other times they may discover weaknesses that could potentially result in a catastrophic accident.
All too often major safety and environmental incidents occur as the result of multiple failures in meeting PSM/RMP requirements. The incremental improvements, although seemingly minor, may often eliminate a link in a chain of multiple failures.
Proper documentation of safety audit results is essential for compliance and for internal purposes. An experienced auditor understands the need to provide tangible evidence of the defects in the PSM/RMP program in order that effective correction action can be taken. The auditor understands that a lack of specific details will diffuse the effort to correct any deficiencies, and thus decrease the effectiveness of the safety audit. The competent auditor understands how to document the deficiencies so that management can effectively correct them.
An experienced auditor knows how to effectively perform each phase of a PSM audit. The first step is to define the scope of the audit. To help decide how extensive the audit will be is determined by past history. If this is to be the first such audit conducted on the plant site, then the scope of the audit will be broad and require detailed specifications regarding the depth of the search for details will go. If there have been previous audits and extensive written records from past audits, and PSM/RPM implementation team reports, then these should be carefully reviewed in order to develop the scope of the safety audit.
Much of the information gathered by the auditor will be through interviews with plant personnel. It is important that an auditor understand how to conduct interviews that will produce the facts and information needed for the audit. The auditor needs the full cooperation of those being interviewed. This requires a non-confrontational, cooperative approach to seeking the facts. The auditor should refrain from even the appearance of passing judgment regarding any disclosures made during the interview process. Some interviewees may require that their identity not be disclosed. The auditor needs to honor this request when reporting the results of the audit.
There are basically three sources of information that an auditor uses to perform his job. These include interviews, reviewing documentation, gathering data from other records, and by field observation. In all cases the auditor should make and keep detailed written records of all information, and its source.
In preparing an audit report, the auditor must use good judgment in assessing the information he has at hand. The report should start with acknowledging the entity that requested a safety audit be performed, and a summary of the findings. From that point forward the report should focus one area at a time and point out both the acceptable findings and the deficiencies that need attention.
In concluding the report the auditor should issue a call to action and encourage management and other PSM/RMP team members to move forward.
PTS can provide experienced auditors with proven track records to perform a safety audit and/or a risk management audit so that your organization can remain in compliance with OSHA and EPA regulations.