736 Introduction to Process Safety Management (PSM)

Compliance Audits

An experienced auditor should scrutinize the Standard Operating Procedures (SOPs) at a facility looking for PSM Program discrepancies in content and format. Special attention should be given to process safety information, mechanical integrity, and contractor qualifications.

To be certain process safety management is effective, OSHA requires employers to certify that they have evaluated compliance with the provisions of PSM at least every three years. To a degree, this will verify that the procedures and practices developed under the standard are adequate and are being followed. However, to be more certain that the PSM Program is effective, Tim Williams, Senior Project Manger (PSM) at Stellar.Net recommends employers follow this auditing timeline:

• Self Audit - Every six months. This is recommended, but not required.
• Standard Operating Procedures Certification - Annually.
• PSM Compliance Audit - Every three years. Required by OSHA.
• PHA and Mechanical Integrity Inspection - Every five years. Update PHAs when a major change is made.
• Management of Change - Anytime a process change is made.

A common mistake in a compliance auditing program is using an company employee who is responsible for the PSM program at the facility. An internal auditor is typically too familiar with the program components, documentation, and implementation methods which may lead to a false sense of security in the effectiveness of the PSM program.

• The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected.
• The two most recent compliance audit reports must be kept on file.

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