We hear it all the time… “yes of course we have a safety management system.” Then we ask one simple question, “can we see your OSH auditing plan for the year/3-years/5-years?” The most common response we get is “OSHA does not require us to conduct overall workplace audits.” That is true and it is also evidence that the facility does NOT have a functioning SMS. Much like OSHA’s PSM standard, an SMS will have an auditing element. But for many facilities that have a PSM/RMP program, they refuse to adopt this practice outside of their efforts to comply with the PSM and RMP standards.
But imagine if OSHA had a standard that required “non-PSM” facilities to conduct wall-to-wall audits at some established frequencies. And with this audit requirement, also comes a requirement (exactly like we find in the PSM standard) to have a requirement to develop Corrective Action Plans (CAPs) for the audit and a formal means to track each corrective action to closure.
