Minimizing Audit Findings by Increasing Operational Discipline and Process Safety Culture

Many major accidents have taken place in the chemical and petrochemical industry over the past 40 years (e.g. Bhopal (India, 1984), Texas City (USA, 2005)), which have been key driving forces for issuing new regulations (governments), publishing standards (industry groups), developing policies (companies), and ultimately for improving Loss Prevention strategies and Process Safety Management (PSM). On this context, a key standard is the OSHA PSM (29 CFR 1910.119), a process-based program aiming at preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

The present paper focuses on the results from several PSM audits performed between 2010 and 2016, at several different Chemical Process Industry (CPI) facilities. On the one hand, we have evaluated how well these facilities complied with the requirements of the OSHA PSM Standard. On the other hand, the data from the audit findings has been compiled and statistically processed in order to compare the main common findings with the results of those analyzed by OSHA’s Refinery and Chemical National Emphasis Programs (NEP) in 2012.

Key audit findings from the CPI are a valued source of information for understanding current safety weaknesses. The lessons learned from this study help us to identify operational discipline and process safety leadership and culture benefits towards minimizing or avoiding audit findings, and therefore, to contributing to an optimized and sustainable Process Safety management system.

Many major accidents have taken place in the chemical and petrochemical industry over the past 40 years (Table 1), which have been key driving forces for issuing new regulations (governments), publishing standards (industry groups), developing policies (companies), and ultimately for improving Loss Prevention strategies and Process Safety Management (PSM). On this context, a key standard is the OSHA PSM (29 CFR 1910.119), a process-based program aiming at preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

The United States (US) Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard 29CFR 1910.119 is a performance-based management system regulation intended to prevent catastrophic releases of highly hazardous chemicals (HHC). This standard contains requirements for the safe management of hazards associated with processes using, storing, manufacturing, handling, or moving highly hazardous chemicals onsite. It emphasizes the management of hazards through an established comprehensive program that integrates technologies, procedures, and management practices. The OSHA PSM 1910.119 standard consists of 14 elements and compliance audits is one of them. It requires compliance audits of all covered facilities every three years; these audits are the ongoing quality assurance process for the process safety management systems.

This study presents a case study that compiles and analyses management system audit findings and related data from a sample of sixteen (16) process facilities. The analysis identifies the most frequently cited elements and compares them with the results obtained by OSHA refinery and chemical National Emphasis Program (NEP). inspections.


To download our resources, you must become a registered site user. After you register, you will receive an email with a login username and password.

Want to Get Full Access to our Technical Resources?

Register Now