TOP Reasons why compliance audits are poor indicators of PSM performance
OSHA promulgated the Process Safety Management of Highly Hazardous Chemicals standard 17 years ago [May 1992]. During this period, initially obscure process safety terms such as Management of change, mechanical integrity, and process safety information have become part of the vernacular for the process industries.
Although strives have been made in making plants safer through process safety programs, no specific method or criteria for assessing performance has been recognized by the process industries. Guidance provided by the PSM standard itself is straightforward. It states, “Employers shall certify ….that the procedures and practices developed under the standard are adequate and are being followed.”1
The emphasis should be placed on ‘adequate and being followed.’ Assessing whether PSM procedures and practices have been developed is relatively easy. Most process plants have adequate procedures covering the administration of their PSM program. Determining the extent that those procedures are being followed is a lengthy process requiring specific skills and experience.
OSHA outlines the intent of the compliance audit allowing companies the flexibility to decide how to assess their performance. The appendix to the PSM standard states, “The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer’s systems are effectively implemented. The audit should be conducted or lead by a person knowledgeable in audit techniques and who is impartial towards the facility or area being audited.”2
Recent high profile incidents such as the BP Texas City incident have shown that assessment efforts must entail more than superficial checks. While this has come as no surprise, much attention has been diverted to the matter.
Blog additions will expand on the following and provide some insight into reasons why PSM audits can not be relied upon for an accurate assessment of performance. This is by no stretch of the imagination the definitive issues, there may likely be others, and all may not be applicable to each plant setting. However, these are issues that should be understood so that countermeasures may be prepared to compensate for any deficiencies presented.
1. Conducted with in-house or corporate staff
2. Conducted too quickly, insufficient time devoted to each category
3. Conducted by outside consultants who may lack process experience
4. Audit concentrated on procedural preparation vs. implementation
5. Program implemenation difficult to assess during audit review
Literature Cited
1US Occupational Safety and Health Administration, “Process Safety Management of Highly Hazardous Chemicals,” 1910.119(o)(1)
2US Occupational Safety and Health Administration, “Process Safety Management of Highly Hazardous Chemicals,” 1910.119 Appendix C; No. 14
