Audit Section

Under the audits section of the PSM standard employers are required to certify that they have evaluated their compliance with the standard at least every three years. The recommendations from the audit must be followed. The audit reports need to be retained as long as the process exists. 

You must submit your written Audit Plan to BSEE at least 30 days before the audit. BSEE reserves the right to modify the list of facilities that you propose to audit. Section 12.5 Audit Frequency, except your audit interval, must not exceed 3 years after the 2-year time period for the first audit. The 3-year auditing cycle begins on the start date of each comprehensive audit (including the initial implementation audit) and ends on the start date of your next comprehensive audit. 

Part 387 of the Federal Motor Safety Regulations (FMCSRs) explains the minimum levels of financial responsibilities required to be maintained by motor carriers operating motor vehicles in interstate, foreign, or intrastate commerce. In this case, financial responsibility means insurance policies or surety bonds a motor carrier must possess and present to the Federal Motor Carrier Safety Administration (FMCSA) in the event of an audit. Section 387.9 lists the minimum public liability requirements for carriers and are based on four factors ... 

An important aspect of environmental, health, and safety laws and regulations is enforcement. Eederal, state, and local regulatory authorities usually have large enforcement sections. In the environmental area, compliance audits are usually conducted aimually. OSHA, both federal and state, usually audits based on a faciHty s accident/incident rate. 

The following sections will describe the project review and audit processes separately, addressing the why, when, and how for each process. 

The following sections provide guidance and some examples for addressing these ongoing activities. The flowchart on the next page shows a typical sequence of ongoing operations and audits. 

Using a standard audit form is certainly acceptable and can prove to be an outstanding tool, especially when getting a handle on a fire extinguisher program, life-safety issues, the lighting of exit signs, availability of first-aid kits, clear aisles, and a variety of issues that are basic in nature. The typical standard audit form will likely have complete sections that are marked not applicable. Unless a unique audit form is created, there is usually no way around sections that will be marked not applicable. ... 

Wliat we have included is only a small part of a much longer document available in its entirety at the address shown or on the Web. We provide the complete table of contents so that you get a good idea of the subjects covered and the amount of detail taken to cover them. After the table of contents, we have taken several sections applying to working with hazardous substances. We believe that OSHA has chosen these items to ensure a safe and healthful workplace. COSHOs will use this format when performing an OSHA compliance audit on incinerator sites. 

There are three references to the management review in other sections of the standard preventive action information (clause 4.14.3), internal audit results (clause 4.17.1), and changes to procedures (clause 4.14.1.1) are required to be submitted for management... 

By being independent of the audited activities, the auditor is unaware of the pressures, the excuses, the informal instructions handed down and can examine operations objectively without bias and without fear of reprisals. It is for this reason that it was considered appropriate for the auditor to have no direct responsibility for the work being audited i.e. audits carried out by a manager, supervisor, or foreman of his/her own department or section do not qualify as internal quality audits in ISO 9001 1994. However, they will qualify under ISO 9000 2000. 

Another link exists between the PIF concept and the sociotechnical assessment methods described in Section 2.7 The checklists used in the TRIPOD methodology are essentially binary questions which evaluate whether the sets of PIFs making up each of the general failure types are adequate or not. The hierarchical sets of factors in HRAM are essentially PIFs which are expressed at increasingly finer levels of definition, as required by the analyst. The audit tool which forms MANAGER also comprises items which can be regarded as PIFs which assess both management level and direct PIFs such as procedures. 

In subsequent sections the application of PIFs to various aspects of error reduction will be described. One of the most important of these applications is the use of comprehensive lists of PIFs as a means of auditing an existing plant to identify problem areas that will give rise to increased error potential. This is one aspect of the proactive approach to error reduction that forms a major theme of this book. This application of PIFs can be used by process workers as part of a participative error reduction program. This is an important feature of the human factors assessment methodology (HFAM) approach discussed in Section 2.7. 

In the case of root cause analysis systems, more comprehensive evaluations of PIFs will normally be carried out as part of a full-scale human factors audit. This could make use of the types of comprehensive PIF evaluation methods described in Chapter 2 (see Section 2.7.7 and Figure 2.12). 

All parts of the quality (ESH/PSM) system should be reviewed and evaluated on a regular basis via internal audits. This section of the standard... 

Pyrido[2,3-c]furoxan (4-azabenzofuroxan, 31) is prepared by pyrolysis of the nitropyridotetrazole (30) (concerning its tauto-merism, see Section I1I,C). Some derivatives of 31 are also known (see Table I). Unsuccessful attempts to make pyrido[3,4-c]furoxan audits A -oxide have been reported, although its 7-nitro and 6,7-benzo (16) derivatives have been prepared. Hydrazine and 3,4-diaroylfuroxans give the diarylpyridazinofuroxans (32). ... 

A system for auditing and reviewing quality procedures is a specific requirement of ISO/IEC 17025, ISO 9001 and GLP. This is a critically important aspect of any quality management system so we will consider these activities in some detail. The first, and most important, thing to realize about Quality Audit and Management Review is that they are two completely different activities. This section deals with auditing while Section 9.5 deals with management review. 

Audit Process Audits in the chemical process industry can be focused on process safety, process safety management, environmental, and health areas. The discussion in this section will focus on the process safety and process safety management area, but it should be recognized that the process can be applied to the other areas as well. "Process safety audits are intended to provide management with increased assurance that operating facilities and process units have... 

The key steps in the audit process are outlined according to preaudit activities, audit activities, and postaudit activities in Fig. 23-48. These activities are described in detail in Guidelines for Auditing Process Safety Management Systems (CCSP, 1993) and will be only briefly discussed in this section. 

Member States shall take all measures necessary to ensure that the laboratories referred to in Article 7 of Directive 89/397/EEC1 comply with the general criteria for the operation of testing laboratories laid down in European standard EN 450013 supplemented by Standard Operating Procedures and the random audit of their compliance by quality assurance personnel, in accordance with the OECD principles Nos. 2 and 7 of good laboratory practice as set out in Section II of Annex 2 of the Decision of the Council of the OECD of 12 Mar 1981 concerning the mutual acceptance of data in the assessment of chemicals.4... 

Section 11.10(d) Limiting system access to authorized individuals Section 11.10(e) Using secured, computer generated, time-stamped, audit trails... 

The paragraph that discusses the "Inspection of a testing facility" is of significant importance. It is found in both the EPA and FDA GLP and, in essence, allows government representatives to enter the facilities and inspect and copy all records within the scope of the work at reasonable times and in a reasonable manner. The text of the paragraph found in the EPA regulations is reproduced in Box 7.5. A key statement here is that the EPA (or FDA) will not consider a study in support of an application for a permit if the testing facility refuses to permit inspection. Thus a facility must permit inspection. This inspection, or "audit" as it is often called, is therefore taken very seriously. See Section 8 for more information. 

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