Full disclosure, I do PSM/RMP audits, but that does not change the facts that I will present in this article. Over the past couple of years, I have seen first-hand companies cancel or fail to schedule their 3-year PSM/RMP audits because their State EPA, Federal EPA or OSHA did a PSM/RMP inspection at their facility and they feel this “inspection” counts as a 3-year audit. They could not be further from reality and here’s why:
1) EPA/OSHA does not have anyone who is a “knowledgeable in the [your] process” and I am sure your team member who is “knowledgeable in the process” was NOT helping OSHA and EPA uncover deficiencies within your management systems during the OSHA/EPA inspection. So for this reason, for none other, is reason enough to understand that an OSHA/EPA inspection is an ENTIRELY DIFFERENT EXERCISE than an internal or 3rd party 3-year audit. The 3-year audit is intended to be a “team effort” with the full intent of uncovering deficiencies in the safety management systems – whereas an OSHA/EPA inspection is something much different and is managed entirely different!
2) Neither EPA or OSHA will audit each covered process nor will they audit each element against each covered process. In fact, they may not even fully audit any process during their “inspection”. From OSHA National Emphasis Program CPL…
The Team Leader shall select a PSM-covered process or processes to evaluate for compliance with the standard. For large continuous processes, the Team Leader may select a portion of the covered process, for example, a unit operation within the covered process. The selected process or portion thereof shall be referred to as the Selected Unit. CSHOs may select more than one unit if they feel it is necessary to get a representative sample of the facility’s covered processes based on the size and complexity of the facility.
However, the employer has a different set of requirements for their 3-year audit(s):
1910.119(o)(1) Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
The 3-year audit is intended to validate that ALL of the safety management systems used to manage process hazards are FULLY in place AND functioning. The intent of our 3-year audit(s) is ENTIRELY DIFFERENT than what OSHA and EPA are on site for during their inspections. So a facility may view the elimination of their 3-year audit as a “low risk – cost savings”, but in reality, they could not be further from reality when it comes to “risk”. I like to point out that OSHA’s old PQV CPL asks the following:
2. Do the audit reports include an evaluation of all the required paragraphs of the PSM standard? [Criteria Reference .119(o)(1)]
I ask anyone who has been through an OSHA/EPA PSM/RMP inspection if they have ever received a report from either agency that included [documentation that] evaluation of all the required paragraphs of the PSM standard was part of the inspection process?
Heck, based on how some facilities answer their PSM NEP questions, OSHA/EPA may spend less than a day on site! When I was still managing safety departments in the petro-chem industry, I went through a state EPA RMP inspection and the entire inspection process was less than 4 hours. I now have clients who are experiencing these brief inspections and want to use these brief inspections as a means to save $. Bottom line: an OSHA/EPA inspection for PSM or RMP does NOT, and was never intended to, replace the required 3-year audit.