Process Safety Management compliance audits

Audits and corrective actions Audits for industrial hygiene compliance can be performed concurrent with, or separately from, process safety management 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. 

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. ... 

Government Institutes, Inc., 1993, ISBN 0-86587-336-4, 120 pages, 49. This OSHA Inspection manual covers process safety management (PSM) compliance guidelines, PSM audit guidelines, clarifications and interpretations of the PSM standard, and SIC codes targeted for the program quality verification inspections. 

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 ... 

Compliance Audits. Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. A small process or plant may need only one knowledgeable person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field... 

The general purpose of an audit may be to determine if the toller has management systems and documented procedures in place to ensure process safety, environmental responsibility, product quality and traceability of materials. The need to audit could be to evaluate compliance with regulations or accordance with client requirements related to specific performance elements. A subjective rating system for ranking management systems audit results is often used. An example of one that might be appropriate is shown below ... 

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. 

Audits or some equivalent means of operational reviews are an important segment of any quality assurance program. They provide feedback to management and are the means of ensuring a continuous improvement of the system and overall facility. In the context of audits for process safety there is a close linkage with quality assurance. Quality assurance encompasses the spectrum of not only ensuring that the requirements are met, and it also provides a system to achieve continuous improvement, in addition to compliance. 

Safety audits are systematic procedures for reviewing management systems and practices implemented to achieve safety. They can include a compliance review, similar to a safety inspection. The audit process also allows for reviewer suggestions and recommendations for improvement. Audits may be part of more general practices to ensure that management systems are in place and followed as written. Audits can apply to systems, processes, products, programs, or services. 

---