Keys to effective third-party process safety audits.

Abstract

The Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) regulation was promulgated in 1992. The U.S. Environmental Protection Agency's (EPA's) corresponding Risk Management Program (RMP) rule followed in 1996. Both programs include requirements for triennial compliance audits. Effective compliance audits are critical in identifying program weaknesses and ensuring the safety of facility personnel and the surrounding public. Large companies with corporate and facility health, safety, and environmental groups typically have the resources and experience to conduct audits internally, either through a corporate audit team or the sharing of personnel between multiple facilities. Small to medium sized businesses frequently do not have the expertise or the resources to perform compliance audits, and rely on third-party consultants to provide these services. This paper will discuss the observations of the authors in performing audits and working with PSM/RMP programs across a number of market sectors (e.g. chemical, petrochemical, pharmaceutical, food and beverage, water treatment), including effective practices, hurdles to successful implementation and execution of programs, and typical program shortcomings. The paper will also discuss steps to improve the audit process and increase effectiveness whether performed by a third party or internally.