Last year, I shared Part I regarding the difference between the two words: Audit and Inspection. Today, I want to explain how and why OSHA/EPA “inspect” and we “audit” our PSM/RMP-covered processes. To put it bluntly, an OSHA/EPA “inspection” does NOT and will NEVER replace our 3-year PSM/RMP audits.
Both EPA and OSHA require RMP/PSM-covered processes to be “audited” AT LEAST every 3 years. These “audits” must cover all 14 elements of the Process Safety Management System and be documented in a written report.
We could go decades without any EPA/OSHA interaction, and even if OSHA/EPA visit our facility, they are there to conduct an “inspection” and almost always, these “inspections” are far less intrusive than what our 3-year “audits” are intended to be. In many cases, the OSHA/EPA inspection may NOT even cover all the elements. With OSHA’s new inspection protocol, a facility may be able to answer the baseline questions and process-specific questions well enough that the “inspection” may last a day.
Lastly, many facilities have been in PSM for 30+ years, at this juncture of our journey, we should be peeling the onion more layers than OSHA/EPA would.