OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast. They are so 20th century (LOL)! This article is about how some of my clients are approaching their 3-year audits required by both standards. This approach embraces the “audit element” of the process safety management system as genuinely intended: a CONTINUOUS IMPROVEMENT function.
Most of my audits with my long-time clients are an intense dive into their management system elements. I treat my audits like peeling an onion – layer by layer. This can result in several findings from each element. It is not unusual for a SAFTENG audit to end with 80-100+ findings, most being compliance-type findings. Most of my findings are not challenged. Instead, they are embraced and welcomed by the client. But this can be a lot to manage. So, to better manage the auditing element and not impact the depth and breadth of our auditing, some clients have chosen a new approach to their 3-year audit(s)…
Do a couple of elements each quarter so that ALL elements have been audited by the end of the 3-year window.