Those familiar with the Process Safety Management (PSM) of Highly Hazardous Chemicals standard understand the importance of compliance audits of the program as well as the large scope of work the PSM program requires. The PSM standard is now over 20 years old. A proper PSM program will address the following areas:
- Process Safety Information (including hazards of the chemicals covered, technology of the process, equipment in the process, and employee involvement)
- Process Hazard Analysis
- Operating Procedures
- Employee Training
- Pre-Startup Safety Review
- Mechanical Integrity of Equipment
- Non-routine Work Authorizations
- Management of Change
- Incident Investigation
- Emergency Preparedness
- Compliance Audits
OSHA requires compliance audits be conducted of the PSM program every 3 years. A proper audit will address all the areas of the PSM program, especially focusing on information updated prior to the previous audits such as management of changes for new and replaced equipment, mechanical integrity of the equipment, and incident investigations. The process hazard analysis (PHA) is required to be revalidated every 5 years; however, including a review of the PHA in the audit can be beneficial.
Many facilities use 1st party audits utilizing checklist procedures where staff within the organization conduct the audits based on forms often created during the development of the PSM program. These audits have the advantage of utilizing personnel familiar with the facility and its specific PSM program. However, this can be a disadvantage as being too familiar with the program and/or pressures from corporate leadership can lead to costly oversights within the program. The Chemical Safety Board (CSB) attributed part of the 2005 Texas City Refinery explosion to flawed internal audits.
For the first time in 20 years, OSHA is taking a serious look into the PSM standard due to incidents like the 2005 Texas City incident as well as the West Texas fertilizer facility incident last year. As part of this review, in late 2013 to March 2014, OSHA was seeking a Request for Information seeking input on updating the standard. One area OSHA is considering updating is the compliance audit requirement. OSHA has been proposing that the three year compliance audits would need to be third party audits. Advantages of a third party audit include:
- Greater balance between corporate and site standards and regulatory requirements
- Greater objectivity than internal audits
- Greater subject matter expertise
- More direct and actionable recommendations
Whether OSHA requires third party audits in the future or not, having someone external to the organization lead the audit team can provide a fresh approach to the PSM program and, ultimately, lead to better PSM standard compliance and a higher degree of safety.
CTI has experience in third party PSM compliance audits, as well as implementation of the PSM program and PHA development and revalidation.