How to Optimize Your PSM Program | The 14 PSM Elements: 13 Compliance Audits | Blog No. 69

[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]

Like many other safety programs, the PSM program requires facilities to perform a self-audit of the implementation of their program. While the triennial audit does not need to be exhaustive, it should be thorough. When asked about the thoroughness of past audits, one Maintenance Manager recalled the audit leader saying “hi” to him as he walked the facility, but did not recall ever sitting down with him. This—as most would agree—does meet the spirit and intent of the compliance audit activity.

The first thing a PSM practitioner should do is locate the two (2) most recent compliance audit reports. Ensure they were completed with sufficient thoroughness and expertise. 

• Was someone involved who is knowledgeable in the process?

•  How about the due date? 

• If the most recent compliance audit was completed more than 3 years ago, then it is past due and must be conducted immediately.

Moreover, there are two areas where facilities often make obvious mistakes. First, many are ignorant of the requirement to certify the compliance audit. This is perhaps up for interpretation, but the simplest way to satisfy the requirement is for the person responsible for the PSM program to sign and date the compliance audit report. Second, as with any other PSM report, resolve the recommendations. Do not simply mark them “complete” or “done,” but record what action was taken to resolve the findings and indicate the date it was completed. Compliance audit reports, recommendations, and recommended resolutions are all fair game for an inspector.

Finally, how does one optimize their compliance audit for ammonia refrigeration systems? While some might be dissatisfied with a non-exhaustive compliance audit, those who operate businesses understand the reality of limited time. It is simply a waste of time to review every data input on every daily log in detail. Instead, savvy auditors will cherry-pick elements for review. This is perhaps more an art than a science. The University of Wisconsin-Madison’s Process Safety Management Audits for Compliance and Continuous Safety Improvement course is to be commended at this point for strategies to improve the compliance audit process. At the very least, the compliance audit leader should be very experienced with ammonia refrigeration systems.

During one EPA inspection, the EPA’s ammonia refrigeration subject matter expert spent a long time studying the evaporative condenser circulation pump. He seemed very concerned with the scale on the pump and the lack of appropriate nameplates. Uneager to correct him and send him to a more relevant area for inspection, no one told him it was only circulating water instead of ammonia until he inquired. While a facility facing a regulatory inspection might be glad to have an inexperienced auditor so they avoid monetary penalties, facilities ought to want a very experienced compliance audit leader so they can effectively sniff out problems prior to a regulatory inspection.