A Comprehensive Guide to Periodic PSM Audits in Facilities

A periodic PSM audit assesses a PSM program’s effectiveness and regulatory compliance. This audit involves reviewing documentation, operating, maintenance, and emergency procedures, training programs, incident reports, and documents supporting the 14 elements of the PSM program to verify compliance and identify opportunities for improvement.

Per OSHA 1910.119, the Process Safety Management (PSM) program mandates regular audits at least every three years, conducted by an individual with expertise in PSM, possessing the necessary knowledge to effectively evaluate and assess compliance and the program’s overall effectiveness.

The Periodic Process Safety Management (PSM) audit is a critical process aimed at validating facility adherence to procedures and ensuring regulatory compliance. In this article, we delve into not only the primary objectives and evaluation of the 14 elements of process safety but also emphasize how the PSM audit process, encompassing documentation review, on-site assessments, and post-audit analysis, assists in safety compliance and continuous improvement in industrial processes. Additionally, we highlight the pivotal role Key Success Factors play in assessing the effectiveness of an organization’s PSM system and identifying critical elements contributing to desired outcomes and goals in process safety.

Primary Objectives

The audit’s primary objective is to demonstrate the adequacy and adherence of the facility’s PSM procedures and practices. PSM audits help verify the organization is following the appropriate regulations, identifying any areas where improvements can be made, and providing recommendations.

Checking compliance: The audit confirms that the organization is adhering to OSHA 1910.119. It verifies that all necessary elements of PSM are in place and are being properly executed.

Finding weaknesses: The audit assists in uncovering weaknesses or shortcomings in the organization’s PSM program. This might involve gaps in documentation, training programs, and inadequate maintenance practices.

Assessing risks: The audit evaluates the effectiveness of the organization’s risk assessments.

Reviewing documentation: During the audit relevant documents, records, and procedures are examined to ensure their accuracy, completeness, and effectiveness. The goal is to verify if the documented practices align with written procedures.

Employee engagement: The audit assesses the level of employee involvement in the process safety management (PSM) system. It evaluates whether there is communication, training opportunities, and active participation in process safety activities.

Following each audit, a comprehensive report must be issued, documenting any findings observed. In response to these findings, a detailed plan of action is required for resolution. Additionally, the facility is obligated to maintain the two most recent audit reports as part of its Process Safety Information, subject to further review in subsequent audit cycles and in the event of on-site incidents.

Evaluation of the 14 Elements

The audit of the Process Safety Management (PSM) program encompasses the thorough evaluation of 14 essential elements. The 14 elements of PSM are defined by the Occupational Safety and Health Administration (OSHA) in the U.S. and serve as a guideline for managing process safety hazards.

As part of the evaluation process, auditors usually examine documentation, conduct interviews with employees, observe operations, and inspect facilities to evaluate compliance and effectiveness. These findings are crucial in identifying any areas that may need improvement or have shortcomings within each element of the PSM program.

These elements include:

  1. Employee Participation: Involves actively engaging employees in developing and implementing PSM programs. This includes training, communication, and establishing mechanisms for employees to provide input on safety issues.
  2. Process Safety Information: Requires maintaining comprehensive information about the chemicals, technology, and equipment used in the processes. This information forms the basis for analyzing and managing the associated hazards.
  3. Process Hazard Analysis: Involves systematically evaluating the potential hazards of processes to identify, assess, and control risks. PHA methods include techniques like HAZOP, HAZID, What-If, and Bow-Tie Analysis.
  4. Operating Procedures: Focuses on developing and maintaining clear and effective written operating procedures to ensure that processes are operated safely. This includes emergency shutdown procedures and startup/shutdown sequences.
  5. Training: Employees require providing training for all employees involved in operating or maintaining a process, ensuring they have the knowledge and skills to perform their tasks safely.
  6. Contractors: This involves ensuring that contractors and their employees know the hazards associated with the processes they will be involved in and follow safety procedures.
  7. Pre-Startup Safety Review: Requires conducting a thorough safety review before introducing a new or modified process to ensure that it is safe to operate.
  8. Mechanical Integrity: Involves establishing and maintaining procedures to ensure the ongoing integrity of critical equipment and preventing equipment failures that could lead to the release of hazardous substances.
  9. Hot Work Permit: Requires implementing a permit system to control and authorize hot work (tasks such as welding or cutting) to prevent fire or explosion hazards.
  10. Management of Change: Involves a systematic process for managing changes to processes, technology, equipment, and facilities to prevent unintended consequences on the health and safety of employees.
  11. Incident Investigation: Requires conducting thorough investigations of incidents to identify root causes and contributing factors and implementing corrective actions to prevent recurrence.
  12. Emergency Planning and Response: This involves establishing and maintaining an emergency action plan to address potential emergencies, including communication, evacuation, and response procedures.
  13. Compliance Audits: Requires conducting regular audits to assess the compliance of processes with applicable regulations and standards.
  14. Trade Secrets: This involves protecting trade secrets while still providing adequate information to employees and contractors to ensure the safe operation of processes.