Introduction

In high-risk industries such as chemical plants, compliance with process safety regulations is not merely a legal requirement but a fundamental aspect of protecting people, assets, and the environment in the USA. According to the American Institute of Chemical Engineers (AIChE), a compliance audit is “a systematic, independent review to verify conformance with prescribed standards of care using a well-defined review process to ensure consistency and to allow the auditor to reach defensible conclusions.”

These audits assess the effectiveness of Process Safety Management (PSM) systems and Risk Management Plans (RMP), verifying that necessary measures are in place to prevent accidents and manage risks effectively. PSM and RMP compliance audits in the USA help facilities identify gaps in their safety programs and provide recommendations for improvement, ensuring that operations align with established standards and regulations.

Key Regulations for PSM and RMP

Ensuring the effectiveness of PSM and RMP programs through compliance audits is critical to safeguarding people, the environment, facilities, and assets in the USA. Consequently, facilities must adhere to the following regulations:

  • OSHA Occupational Safety and Health Standard (29 CFR 1910.119): This regulation covers the Process Safety Management of highly hazardous chemicals.
  • EPA’s Risk Management Rule (40 CFR Part 68): This rule focuses on Chemical Accident Prevention Provisions.
  • California Accidental Release Prevention (CalARP Program – California Code of Regulations, Title 19, Division 5, Chapter 2, Sections 5050.1 to 5160.1): This state-specific regulation aims to prevent accidental releases of hazardous substances.
    • Cal/OSHA Process Safety Management (CCR 5189): This addresses PSM requirements for California workplaces handling hazardous chemicals.
    • CalPSM-R (CCR 5189.1): This specifies additional PSM requirements for refineries in California, enhancing safety measures in this high-risk industry sector.

This involves scheduling, performing, and documenting periodic evaluations to ensure systems are effective and compliant with established standards. Noncompliance with these regulations can result in severe penalties and significant operational disruptions. Hence, conducting thorough and regular PSM audits is essential to protect facilities against process safety risks, identify opportunities for improvement, and ensure regulatory compliance, driving continuous enhancement in safety performance.

With the EPA’s final ruling, external compliance audits for Risk Management Plans (RMP) must be conducted by third-party auditors who are knowledgeable, experienced, and independent, ensuring they meet the criteria for competency and impartiality​.

Collaborative Efforts in PSM Audits

The effectiveness of a PSM audit relies on the collaborative efforts of a diverse team, including the audit team, site PSM personnel, site management, and operations and maintenance representatives, with additional support from corporate representatives and other site personnel, to ensure thorough evaluation and continuous improvement in safety performance.

Why Are OSHA Inspections Random? 

OSHA conducts random inspections not to “surprise” companies; rather, these inspections enhance workplace safety by ensuring consistent compliance with safety standards, not only during scheduled checks.

Random inspections create a sense of unpredictability, encouraging employers to adhere to safety regulations at all times. This approach has been shown to significantly improve overall workplace safety, as businesses are less likely to postpone necessary safety measures when they know an inspection could occur at any moment.

Additionally, random inspections help identify and promptly address safety hazards, reducing the risk of accidents and injuries. The benefits of random inspections include fostering a proactive safety culture, deterring noncompliance, and ensuring that any hidden or unforeseen risks are identified and mitigated quickly.

By implementing random inspections, OSHA can enforce regulations more effectively, promote continuous safety improvement, and protect workers more efficiently than scheduled inspections.

Saltegra’s Approach to Process Safety Audits

Understanding the critical role of random inspections in maintaining workplace safety underscores the importance of regular and thorough audits. Saltegra’s approach to PSM compliance audits in the USA is structured into a comprehensive three-step process: offsite audit, onsite audit, and post-audit activities. 

Offsite Audit 

The offsite audit begins with meticulous information collection, working closely with site personnel to gather essential Process Safety Information (PSI). This step includes collecting process descriptions, flow diagrams, material property data, equipment layout drawings, and written policies and procedures, minimizing the time required for the onsite visit.

Preparatory work also involves gathering extensive documentation such as risk assessments, hot work permits, management of change documents, incident investigations, competence assurance records, pre-startup safety reviews, equipment inspections, preventative maintenance records, and previous PHA and PSM audit reports.

Onsite Audit 

The onsite audit is a thorough evaluation process that includes a detailed facility walkthrough to observe and assess physical conditions and processes. During this phase, the audit team interviews site operations, maintenance, and contract personnel. They also review documentation to ensure compliance with OSHA, EPA, and CalARP standards.

This step also involves completing detailed checklists addressing all aspects of these standards, assessing emergency response procedures, and evaluating management systems, including management of change, incident investigation, training programs, internal audits, performance metrics, and the management of safety-critical equipment. This comprehensive onsite evaluation ensures a robust assessment of the facility’s adherence to regulatory requirements and best practices.

Post-Audit Activities 

Post-audit activities focus on compiling and documenting the findings from the audit. This includes drafting a comprehensive report that details observations, findings, and recommendations for addressing any identified gaps in the PSM, RMP, and CalARP-covered portions of the site. An action tracking system is implemented to manage and monitor audit findings, ensuring identified issues are addressed promptly.

Additionally, the final step involves maintaining documentation of findings and closeouts for future audit cycles, providing insights and recommendations to enhance the site’s programs based on legislated requirements and industry best practices. This structured and thorough approach ensures continuous improvement in safety performance, operational excellence, and regulatory compliance.

The Importance of Regular Audits 

To maintain compliance and enhance safety performance, facilities should perform these audits at least every three years, employing auditors with specialized expertise in PSM. This systematic approach not only helps identify and mitigate potential risks but also supports continuous improvement, operational excellence, and adherence to regulatory standards set by bodies like OSHA, EPA, and state-specific programs such as CalARP, Cal/OSHA, and CalPSM-R, ensuring that facilities operate safely and efficiently.

Partner With Saltegra for Your Next Audit 

Partnering with Saltegra for PSM audits offers numerous benefits that enhance both compliance and operational excellence of companies in the USA. We offer the following:

  • Subject-Matter Expertise: Saltegra’s team brings strong credentials and extensive experience in process safety, combined with valuable insights from seasoned personnel, ensuring a rigorous and comprehensive audit process.
  • Effective Communication and Collaboration: The audit process is seamless and efficient, reflecting Saltegra’s core value of client care and collaboration. This approach ensures all stakeholders are engaged and informed throughout the audit, facilitating a cooperative and productive environment.
  • Strategic Project Management: Saltegra ensures thoroughness and minimal disruption to operations through meticulous planning and strategic timing, fostering full stakeholder engagement. This approach maximizes the efficiency and effectiveness of the audit process.

These advantages collectively support regulatory compliance, making Saltegra a reliable partner for PSM compliance audits in the USA.

Author