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.
As I said, this approach embraces Auditing as a Continuous Improvement effort. It also allows the client to fully understand the failure mode of how the findings came about and how the facility failed to recognize these failures via its internal QA controls.
Instead of ending a week (or two) audit with 80-100+ findings, the facility will end each quarter with 5-10-15 findings, AND this approach allows us to have a larger sample size, which only improves our confidence level in the management system. In other words, ten findings are a lot easier to manage and understand over a 3-6 month period.
This approach can also identify serious deficiencies sooner, allowing the facility to address them sooner!
Nothing in either standard prohibits this approach to the 3-year audit, as all elements are being audited every three years. We have just embraced the audit and continuous improvement functions, where the word CONTINOUS means what it says.
This is how we have found the element groupings work best:
1) Employee Participation, Trade Secrets, Auditing (1-Day)
2) PSI and PHA (3-Days)
3) SOP and Training (2-Days)
4) Contractors (1-Day)
5) MOC and PSSR (1-2 Days, depending on #’s)
6) Safe Work Practices and HW Permits (1-2 Days, depending on scope)
7) MI (up to 3 days, depending on #’s)
8) Incident Investigations and Corrective Actions Tracking (PHA, II, Audits) (1-Day)
9) Emergency Planning and Response with RMP OCA’s if applicable (2-3 Days, depending on scope and size)
Remember, there are 12 quarters in a 3-year window, so breaking the elements into nine groupings allows the facility to have six months for the oversized items like Mechanical Integrity (MI) and PSI/PHA audits. The other audit groups that often need more time are Safe Work Practices and HW Permits. However, every facility can pick and choose how they want to group their elements and when they want to audit those elements.
Yes, this approach costs more, and yes, there are more “audit days.” So, this approach is usually embraced by more mature businesses in their process safety cultures. However, it is wildly popular amongst those clients who have embraced this approach. They all like to say jokingly…
“Bryan’s audits in smaller bites are much easier to digest and comprehend.”
My audit findings are a teaching moment, so each finding is explained in detail to anyone who wishes to learn the WHY behind OSHA/EPA requiring it. This approach allows ample time for the facility to fully understand the deficiency and what it will take to correct it from a “management system” fix rather than a 1-time fix approach.
Anyone interested in learning more about this 21st Century auditing approach can reach me at [email protected].