Compliance programs management systems

Based on the audit findings, the team typically issuesa report that summarizes the status of current management systems and identifies pacesetter programs and areas of non-compliance or exceptions. These findings should be provided both to the facility manager and to the PSM team, for consolidation into overall recommendations. A sample audit report is shown in Figure 4-5. 

Once all the elements of the Process Safety Management system are in place and are being implemented, the Compliance Audit [29 CFR 1910.119 (o)] element provides a means to evaluate the program s compliance level. Every three years, the program must be audited to ensure that it is being implemented as per the regulation. The audits can be done internally, but some companies hire outside consultants to get the viewpoint of an unbiased expert. ... 

It has been mentioned already that there are different levels of sophistication with regard to the involvement of computer applications in GLP studies and test facilities. These levels may range from the complex problems involved in the GLP compliant management of computer networks and of laboratory information management systems (LIMS) to the question of whether a simple instrument controlled by a built-in, pre-programmed chip should be treated in the same, extensive way with regard to software validation . It is certainly self-evident, as these two examples demonstrate, that not all types of IT applications have to be considered as equal with regard to GLP compliance it may indeed be impossible to do so. As it is commonplace nowadays that the silicon chip penetrates the operation of practically all kinds of work, the elucidation of its involvement in the operations of test facilities becomes an essential part of the implementation of GLP. 

A good transportation risk management system includes periodic audits of the management system, its technical elements, and compliance across the supply chain. The purpose of an audit program is to provide feedback on transportation risk management efforts to improve or enhance current operations such as determining ... 

The TSCA compliance program benefits from whatever support is available in the organizational structure. To the extent that there are structures within the company that can be adapted to support TSCA compliance, they should be exploited for that purpose. Some common infrastructure areas are organizational charts, job descriptions, performance management systems, and new hire orientation. 

The Audit Policy does not say much about what a company must do to prevent recurrence of the violation, other than that it may need to improve its auditing program or compliance management system. 

The company acquiring the facility should recruit process safety experts to evaluate the quality of the PSM program. This evaluation goes beyond a simple compliance-style audit— it aims to determine if the management system is working properly. 

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