We see this far too often… a management system failure related to 3-year PSM/RMP audits. A company with multiple facilities should be “trending” its 3-year audit findings to IDENTIFY opportunities for improvement across the company. I did this years ago when I was a member of the Corporate EHS Team for a semi-conductor. And was it ever eye-opening? Just simply doing a number count of findings for each PSM/RMP element can paint a picture of opportunity for risk reduction. Once we had a basic picture drawn of where our opportunities were, we took the next step in analyzing WHY those opportunities were present. Was it a lack of knowledge, lack of maturity in PS, lack of $, lack of management understanding or commitment, etc.?
And for those who want to claim the audits were “not valid” because the facility felt “the auditors were too picky”, well there is a great starting point in our analysis. Now it could be that some facilities had competent auditors and others had “less than competent” auditors and yes this could impact our data and analysis; but that in of itself is an OPPORTUNITY to improve our auditing element. (i.e. make sure all PSM/RMP audits are conducted by competent auditors! As we all know the games that get played to “check the box” for the 3-year PSM/RMPaudit).
Clients who are serious about their PS have hired SAFTENG to conduct audits at the majority of their PSM/RMP-covered facilities. By having the same team conduct the audits, we removed the variability in the auditors, and thus a fair performance comparison could be made. But it also allowed us to summarize the results of the audits over a 3-year period so that senior management can get a clear picture of risk reduction opportunities. These opportunities were turned into Corrective Action Plans (CAP) that span up to 5-7 years. It guided the company to establish PS leading indicators that can be measured and bring actual risk reduction on a company scale, as well as at the process level. The results of the auditing analysis impacted annual and 5-year budgeting; something the company had never looked at “as a company” (that was eye-opening for them!). It brought into focus, both the numbers and skill sets, necessary to manage process safety within the EHS groups, as well as operations, maintenance, and engineering.
Auditing is a KEY element of any safety (Process Safety) management system. If this element is embraced and utilized to live and breathe the mindset of Continuous Improvement, well then the company is off on the right foot. But when the audit element is viewed as simply a “check the box” compliance requirement, the business is wasting time and money on the exercise. Granted they may make OSHA or EPA happy, but they are missing the point and this may be an indication that management system maturity is lacking. Just take your last round of 3-year audits and simply count the number of findings for each PSM/RMP element. Take the Top 3 elements that had the most findings and dig into the WHAT were they specifically and WHY were these the top items. This simple and very easy starting point will OPEN many other opportunities to reduce risks and quite possibly turn the auditing element into the LEARNING ELEMENT.