Although most companies that handle hazardous materials have implemented process safety management (PSM) systems, they are still having accidents. These same companies have good audit programs that verify compliance and implementation of good management systems, but hardly any look at the quality of the audited programs. A company can have a PSM program that meets regulatory requirements, but is not effective in preventing accidents. Having a good management system in place may help, but is still not enough. The problem is the quality of many PSM programs is poor and there is no mechanism in the audit program to identify these quality issues. For example, after an accident has occurred, how often do you find that your process hazard analysis failed to identify the actual or similar scenario, concluded that there were adequate controls in place, or failed to follow-up on recommendations that might have mitigated the accident? Identifying quality issues in PSM systems is difficult, because it requires that the auditor have considerable experience in the PSM elements being audited and it is more time consuming than a typical compliance audit. However, given the extensive resources that most companies have already spent in developing their PSM programs, it makes sense to make sure that they are not only in compliance, but also effective in preventing accidents.
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