 | What it means:
 | Employers
need to select a PSM trained individual or assemble a
PSM trained team of people to audit the process safety
management system and program. A small process or cold
storage facility may need only one knowledgeable person to conduct an
audit. The audit is to include an evaluation of the
design and effectiveness of the process safety
management system and a field inspection of the safety
and health conditions and practices to verify that the
employer's systems are effectively implemented and well
documented. The
audit should be conducted or lead by a person
knowledgeable in audit techniques and who is impartial
towards the facility or area being audited. The
essential elements of an audit program include review of
PSM program details, review of support
documentation, conducting the audit, interviews,
evaluation and
corrective action, follow-up and documentation tracking recommendations
to closure.
|
| Planning
in advance is essential to the success of the auditing
process. Each employer needs to establish the format,
staffing, scheduling and verification methods prior to
conducting the audit. The format should be designed to
provide the lead auditor with a procedure or checklist
which details the requirements of each section of the
standard. The names of the audit team members should be
listed as part of the format as well. The checklist, if
properly designed, could serve as the verification sheet
which provides the auditor with the necessary
information to expedite the review and assure that no
requirements of the standard are omitted. This
verification sheet format could also identify those
elements that will require evaluation or a response to
correct deficiencies. This sheet could also be used for
developing the follow-up and documentation requirements.
|
| An
effective audit includes a review of the
relevant
documentation and process safety information,
inspection
of the physical facilities, and interviews with
all
levels of plant personnel and systematically
analyze compliance with
the provisions of the standard and any other
corporate
policies that are relevant. For example, the
auditor will review all aspects of the training program as part
of the overall audit. The auditor will review
the written
training program for adequacy of content,
frequency of
training, effectiveness of training in terms of
its
goals and objectives as well as to how it fits
into
meeting the standard's requirements,
documentation, etc.
Through interviews, the auditor can determine
the
employee's knowledge and awareness of the safety
procedures, duties, rules, emergency response
assignments, etc. During the inspection, the
auditor
will observe actual practices such as
safety and health
policies, procedures, and work authorization
practices.
This approach enables the auditor to identify
deficiencies
and determine where corrective actions or
improvements
are necessary.
|
| An
audit is a technique used to gather sufficient facts and
information, including statistical information, to
verify compliance with standards. Auditors should select
as part of their preplanning a sample size sufficient to
give a degree of confidence that the audit reflects the
level of compliance with the standard. The auditor,
through this systematic analysis, should document areas
which require corrective action as well as those areas
where the process safety management system is effective
and working in an effective manner. This provides a
record of the audit procedures and findings, and serves
as a baseline of operation data for future audits. It
will assist future auditors in determining changes or
trends from previous audits.
|
| Corrective
action is one of the most important parts of the audit.
It includes not only addressing the identified
deficiencies, but also planning, followup, and
documentation. The corrective action process normally
begins with a management review of the audit findings.
The purpose of this review is to determine what actions
are appropriate, and to establish priorities,
timetables, resource allocations and requirements and
responsibilities. In some cases, corrective action may
involve a simple change in procedure or minor
maintenance effort to remedy the concern. Management of
change procedures need to be used, as appropriate, even
for what may seem to be a minor change. Many of the
deficiencies can be acted on promptly, while some may
require engineering studies or indepth review of actual
procedures and practices. There may be instances where
no action is necessary and this is a valid response to
an audit finding. All actions taken, including an
explanation where no action is taken on a finding, needs
to be documented as to what was done and why.
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| It
is important to assure that each deficiency identified
is addressed, the corrective action to be taken noted,
and the audit person or team responsible be properly
documented by the employer. To control the corrective
action process, the employer should consider the use of
a tracking system. This tracking system might include
periodic status reports shared with affected levels of
management, specific reports such as completion of an
engineering study, and a final implementation report to
provide closure for audit findings that have been
through management of change, if appropriate, and then
shared with affected employees and management. This type
of tracking system provides the employer with the status
of the corrective action. It also provides the
documentation required to verify that appropriate
corrective actions were taken on deficiencies identified
in the audit. |
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