Energy Risk Engineering Insights

Let’s discuss a compliance audit program at a PSM covered petrochemical facility.

Process Safety Management is a systematic approach to managing the risks associated with highly hazardous chemicals in the workplace. It is essential for petrochemical facilities to implement a robust compliance audit program to ensure they are meeting regulatory requirements and maintaining a safe working environment. Here are some key aspects to consider in such a program:

1. Regulatory Compliance: The compliance audit program should be designed to ensure that the facility complies with all relevant local, state, and federal regulations pertaining to process safety management, such as OSHA’s (Occupational Safety and Health Administration) Process Safety Management standard (29 CFR 1910.119).
2. Audit Frequency: Determine the frequency of compliance audits. These audits may be conducted annually or at other appropriate intervals, based on the complexity and risk level of the facility’s processes.
3. Audit Scope: Clearly define the scope of the compliance audit. It should cover all elements of the PSM standard, including process safety information, process hazard analysis, operating procedures, training programs, contractor management, emergency planning, and mechanical integrity.
4. Audit Team: Assemble a competent audit team with members who have a thorough understanding of process safety and PSM regulations. The team should include internal staff and may involve external experts or consultants.
5. Audit Checklist: Develop a comprehensive checklist that covers all the essential elements of the PSM standard. The checklist should be based on regulatory requirements and industry best practices.
6. Document Review: During the audit, the team should review relevant documentation, such as process safety information, operating procedures, maintenance records, incident reports, and training records.
7. Interviews: Conduct interviews with facility personnel to assess their understanding of the process safety management system and its implementation.
8. Facility Inspection: Perform a physical inspection of the facility to evaluate equipment, process controls, safety devices, emergency systems, and overall safety practices.
9. Non-compliance Identification: Identify any areas where the facility is not in compliance with PSM requirements or where improvements can be made to enhance safety.
10. Corrective Action: After the audit, develop a corrective action plan to address any deficiencies or non-compliance issues identified during the audit. Assign responsibility for implementing corrective actions and set a timeline for completion.
11. Follow-up Audits: Schedule follow-up audits to ensure that corrective actions have been effectively implemented and that the facility remains in compliance with PSM regulations.
12. Continuous Improvement: Encourage a culture of continuous improvement in process safety management. Use the findings from audits to drive improvements in safety procedures, training, and maintenance practices.
13. Record Keeping: Maintain thorough records of the audit process, including audit reports, corrective action plans, and evidence of implementation.

By implementing a well-structured compliance audit program, the petrochemical facility can identify and address potential safety hazards, reduce the risk of incidents, and demonstrate a commitment to process safety management and regulatory compliance.