auditing psm systems

8/11/2019 Auditing PSM Systems

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Auditing Process SafetyManagement Systems

David E. Downs, CIH, CSPPresident

EHS Management Partners, Inc.


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Copyright - EHS Management Partners,Inc.

Process Safety Management -A Brief Review

Rationale for Process Safety Management Structure of OSHAs PSM Standard Requirement for PSM Audit PSM Audit as a Management System Component


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Bhopal, India


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Chemical CompanyMustang, Nevada

Downloaded from the U.S. Chemical Safety and Hazard Investigation Board Web Site


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Chemical Plant Explosion

Downloaded from the U.S. Chemical Safety and Hazard Investigation Board Web Site


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Process Safety Management Structure Employee Involvement Process Safety Information Process Hazard Analysis Operating Procedures Employee Training

Contractors Pre-Startup Safety Mechanical Integrity Hot Work Permits Management of Change

Incident Investigation Emergency Preparedness

Compliance Audits!


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PSM Audit Requirements

Certify compliance every three years procedures are adequate are being followed

Conducted by at least one person familiar with process Report of findings Document response to findings Retain last two audit reports


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PSM in the Context of an EHSManagement System

Covered process - usually rates as a significant EHSaspect

Objectives relate to risk reduction

Significant implementation issues Responsibilities; Training; Process Documentation; ... PSM Audit is part of Checking and Corrective Action Goal needs to be Continuous Improvement


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Design of a PSM Audit

Start with OSHA Guidance Document OSHA Instruction CPL 2-2.45A CH-1

Appendix A Essentially a workbook and checklist for the OSHA

Compliance Officer

Includes Program Summaries by section Record Review Guidelines On-site Conditions to Review Interview Questions


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Copyright - EHS Management Partners,Inc. 1


Develop Implementation Criteria Level 1- Issue or criteria has not been addressed Level 2- Addressed in cursory or ad hoc manner, little

coordination or management Level 3- Most elements addressed; some areas need

completion, documentation or communication Level 4- Criteria has been effectively and consistently

implemented

Level 5- Addressed in particularly effective manner; bestmanagement practices in industry or company.


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Example Question & Implementation Levels

Q: Have appropriate checks and inspections been made to assureequipment is installed properly and consistent with designspecifications and manufacturer's instructions?

L evel 1- There is no evidence of a process for installation verification.

L evel 2- Some staff report that inspections are done, but there is no consistentdocumentation or process.

L evel 3- There is evidence of a procedure for equipment installation checks andinspections, based on review of documentation. Not all new equipment is

consistently reviewed; or, reviews may not be complete.


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Example Question & Implementation Levels

Q: Have appropriate checks and inspections been made to assureequipment is installed properly and consistent with designspecifications and manufacturer's instructions?

L evel 4- There is an effective and consistent review process which verifies that new

equipment is installed properly and in accordance with specifications. Reviews aredocumented.

L evel 5- The process for new equipment installation has been designed andimplemented in a particularly effective manner and represents best practices for thisindustry or organization.


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Conclusions

Need to comply with OSHA Audit Requirements Recognize the reality of incremental

improvements

Institute a Continuous Improvement Process

auditing psm systems

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