I’ve walked through numerous regulatory inspections with my clients and have figured out the easiest way to make an inspection go smoothly. It’s not about keeping your discharge pressure down or having all of your PSM documentation in perfect condition. It’s actually much simpler: clean it up!
As the saying goes, cleanliness is next to godliness. I can’t explain why it works, but I can attest that when a machinery room looks clean, the inspector rarely takes their time looking for issues. When the machinery room is dirty, on the other hand, they almost always hunker down, pull out their phone to take pictures, and start writing down violations.
Here’s a System Cleanup Checklist:
Focus on the machinery room first.
Get rid of cobwebs.
Clean up any spilled liquid or oil absorbent from the ground.
Remove any chemicals that shouldn’t be in the machinery room (especially flammable ones!).
Relocate tools from the machinery room that shouldn’t be there (e.g., welding torch).
Defrost areas of excessive ice (certain valve groups, oil pots, pumps, etc.).
If you have time, go around and touch up paint around the system (again, start in the machinery room).
If you have the means, seal up any areas of loose insulation.
It may surprise you to learn that this principle also applies to your PSM program documentation: clean it up! If an inspector asks you to locate your ammonia SDS and it takes you five minutes to find it, this causes them to believe your program is in disarray. If, on the other hand, they ask to see your P&IDs and you can pull it up in 20 seconds, it will impress upon them that your program is in good shape (even if there are a boatload of inaccuracies in the P&IDs!).
When it comes to keeping your PSM documentation organized, there are many different methods. If you haven’t converted from paper copies yet, it’s time to go digital. You can use a PSM software, or you can use the file structure your facility is already using. Here’s an industry secret: your folder structure should mirror the order of the regulations themselves. The reason you want to do this is because the inspector will be using a checklist to make sure you have everything. Their checklist is going to be in the order of the regulations. So if your program is in the same order, you can actually have the next document they’re looking for before they ask for it! This blows their socks off every time and instills a confidence in them that you’re on top of your PSM program. For example, your process safety information folder should be organized this way:
I hope these tips help your next inspection go smoothly! Contact us if you’d like help organizing your PSM program.
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