Most companies have completed at least three process safety management (PSM) compliance audits of their covered facilities since the promulgation of the OSHA PSM standard. These companies, however, are not seeing noticeable improvements in their PSM programs. In fact, many companies feel that their PSM programs have become less effective. What has happened and why? Are there any lessons learned from the Enron collapse and its auditing program? What needs to be done?
The OSHA process safety management Standard requires compliance audits of all covered facilities every three years. When this requirement took effect on May 26, 1995, some companies were already conducting environmental, health and safety (EHS) audits of their facilities and added this new requirement to their existing audit program. However, for many other companies auditing was something new and they needed help. The typical response was to hire consultants either to conduct audits or to train their staff to conduct the audits. As with many other PSM requirements, such as pre startup safety reviews, there was limited guidance on how to conduct an effective PSM audit. Various approaches were used ranging from simple checklists listing PSM requirements and focusing on compliance to more in-depth audit programs that evaluated management systems in addition to compliance. These initial PSM audits were often very simple, particularly for those facilities that had yet to develop and implement PSM programs. These audits, thus, had very basic findings for some PSM elements: “There is no program is in place for this element.” As guidelines for PSM auditing were developed, such as the “Guidelines for Auditing Process Safety Management Systems” published by the Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE), some level of consistency was established.
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