Compared to other regulations, the complexity and breadth of the 14 elements of PSM put other safety programs to shame. Even facilities with the most diligent PSM team can still neglect major requirements of the standard. For this reason, a thorough review of the policies and practices must be conducted in what is called a compliance audit. Here is a review of the requirements found in Title 40 CFR §68.79 and Title 29 CFR §1910.119(o):
The facility must certify that they have assessed compliance with the regulations outlined in the PSM standard every three (3) years to ensure that the established procedures and practices are sufficient and being followed. The compliance audit should be carried out by an individual with expertise in the process, and a report of the audit findings must be created. The owner or operator is responsible for promptly determining and documenting an appropriate response to each finding of the compliance audit, as well as documenting the correction of any deficiencies. Additionally, the owner or operator must retain the two (2) most recent compliance audit reports.
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