Chemical process safety compliance audits

Common sense and the OSHA Chemical Process Safety Management Law requires an audit of compliance to the Management of Change. Periodic review and documentation of a sites activities in managing aspects of personnel and process safety is often a part of an organization s culture. A good audit can measure the actual versus intended effectiveness of various programs. 

Introduction Review and audit processes are used in the chemical process industry to evaluate, examine, and verify the design of process equipment, operating procedures, and management systems. These processes assure compliance with company standards and guidelines as well as government regulations. Reviews and audits can encompass the areas of process and personnel safety, environmental and industrial hygiene protection, quality assurance, maintenance procedures, and so on. 

Management must institute procedures to assess levels of compliance with agreed standards for safety. Techniques include environmental and/or biological monitoring, health surveillance, safety audits, safety inspections, and procedures for accident reporting, investigation and analysis. Communication is essential, e.g. by provision of information (on specific chemicals, processes, etc.), safety meetings, notices, safety bulletins etc. 

To provide the views of others with impressive reputations who have been successful in making safety audits, two colleagues were asked to write to me on the subject. Mr. Thomas W. Lawrence, Jr., CSP, PE, formerly at Monsanto, is now a Principal at Risk, Reliability Safety Engineering in League City, Texas. That firm does many safety audits to assist clients in assuring compliance with OSHA s Final Rule for Process Safety Management of Highly Hazardous Chemicals. This is what Mr. Lawrence wrote ... 

Both the PSM and RMP rules state that employers must certify that they have evaluated compliance to verify that the procedures and practices developed under the standard are adequate and are being followed. This chapter provided information about the relationship of audits to QA, the audits themselves, audit conduct, lessons learned, and some related information about the Chemical Safety and Hazard Investigation Board. It was stressed that the OSHA Inspection Manual is an essential reference at any site with process safety responsibilities. 

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