Compliance Audit is one of the fourteen required elements of the Process Safety Management (29 CFR 1910.119) and Risk Management Plan (40 CFR 68) Program Level 2 and Program Level 3 programs. The Process Safety Management (PSM) and Risk Management Plan (RMP) programs are intended to be self-governing regulatory programs where facility management personnel monitor internal program performance and audit their PSM and RMP program every three years. The compliance audit is typically conducted by an unbiased third-party but may also be performed in house with appropriate training and expertise. Trinity routinely supports clients in developing and implementing successful compliance audit programs.
The intent of the compliance audit is to internally assess and discover potential gaps in an organization's PSM/RMP program. It reviews PSM/RMP covered operations, documentation, and culture, and compares them against regulatory requirements, recognized and generally accepted good engineering practices (RAGAGEP), and site-specific written procedures. In short, it's a reality check of how well a facility “walks their talk” with respect to their PSM/RMP programs.
PSM/RMP Compliance Audit Scheduling and Recordkeeping
To ensure a facility stays in compliance with the requirements of the PSM/RMP standards, an appropriate audit schedule is developed from the date when the first PSM/RMP covered chemical exceeds its threshold quantity in the system. From this initial date, the facility must conduct a compliance audit within three years and every three years thereafter.
Staff should allow three to six months prior to the three-year milestone to adequately prepare for a compliance audit, to compile necessary process safety and risk management program information, hold audit project planning meetings, complete the audit, and prepare the final report. Completing the site audit two to four weeks prior to the compliance date should provide the facility the necessary time to safely finalize the audit within compliance.
A facility must keep records of the last two compliance audits on site, including a method of tracking the identified action items and their status, completion dates, and responsible party. The site should be able to demonstrate that all previous compliance audit items were addressed appropriately. Carryover action items from one compliance audit to the next could be perceived by OSHA and/or EPA as compliance violations, up to and including willful violations.
PSM/RMP Compliance Audit Preparation
While there is no one “correct” way to prepare for a compliance audit, Trinity's auditors will help ensure you have a well-planned, successful audit. Some facilities develop a “war room” or a LAN location to gather representative PSM/RMP documents and evidence for easy access to the audit team. A kickoff meeting with the auditor and site team is helpful to review the audit agenda and documents requested for review prior to the onsite work. Pre-audit meetings that discuss the audit procedure and schedule with key audit project stakeholders and affected employees will help cultivate PSM/RMP culture and a team-based approach to auditing.
Ideally all affected employees will have at least fundamental PSM/RMP awareness prior to the audit. Trinity Consultants frequently provides associated training for affected employees.
PSM/RMP Compliance Audit Approach
Trinity Consultants utilizes an optimized auditing approach, using recognized and generally accepted practices at its core. Our approach is a simple three step process that includes aligning with facility planning goals, conducting a qualified representative audit, and delivering a final report with reasonable and clear recommendations that put your facility on a path to compliance success.
We provide detailed metrics identifying key focus areas that are statistically significant to improve a facility's overall safety and compliance score. With our audit results, you will understand how to prioritize your time and resources to improve your PSM/RMP program for greatest improvement. For example, a facility may have several findings in mechanical integrity but few in process safety information. We will address findings in a manner that maximizes resolution with minimal effort.
Trinity's auditors are respected experts in the industry with decades of PSM/RMP knowledge and experience. Our auditors have varied backgrounds and experience including PSM/RMP management, EHS management, operations, maintenance, and plant management in multiple industries such as chemical refining, oil and gas, power generation, and ammonia refrigeration. We understand that a good auditor understands equipment, operations, and people just as much as the regulations.
Trinity's auditors have supported clients on OSHA and EPA surprise inspections and have successfully worked with regulators to reduce violation status, create abatement plans, and implement recommendations from OSHA violation notices and EPA agreed orders. Trinity Consultants' auditors understand what OSHA and EPA look for and we use this valuable perspective to enhance focus and provide relevant results. We are deeply connected to PSM/RMP goals and see every compliance audit as a fresh opportunity to deliver industry best practices and meaningful results to our clients.
After the Audit: PSM/RMP Continuous Improvement
Trinity Consultants' PSM/RMP experts help build fully-compliant programs from scratch, improve existing programs, and optimize mature, successfully implemented PSM programs. We have performed hundreds of PSM and RMP audits and have represented clients successfully through multiple OSHA and EPA inspections through which we have developed an efficient process for continuous improvement of client programs.
When the audit is complete and the final report is in your hands, it is time to start resolving the findings. Using technology, we document the PSM and RMP rules, combine the rules with real-world tasks, and enable management to track and validate PSM compliance performance on a routine basis. When the next compliance audit cycle occurs, our clients are well informed, ready to audit, and typically perform better on compliance audit score results. Contact us to learn about our continuous improvement methodology.
Successful PSM/RMP Compliance Solutions
If your compliance audit is past due or if you're unsure how to address previous compliance audit recommendations, contact Trinity Consultants at (800) 229-6655 or at trinityconsultants.com/ContactUs. We can assist you in developing solutions that avoid or minimize enforcement consequences from lingering audit recommendations. Our compliance auditors will work with you to find an optimal compliance solution and address the potential compliance audit issues.
If your facility is likely to carry over compliance audit recommendations to the next audit, please contact us for assistance. We can often address recommendations utilizing your existing program or by developing a solution for resolution. Carrying over unresolved compliance audit recommendations into the next audit can result in regulatory violations, fines, and a record of non-compliance for the next two audit cycles. A serious compliance situation like this is avoidable; if this situation applies to your facility, please contact us immediately for assistance.