7 PSM Audit Violations and How to Avoid Them

Quality assurance is one key to a successful food safety audit

Process Safety Management (PSM) compliance audits are specific and comprehensive, focusing on 14 elements of OSHA’s PSM Standards. A well-planned and organized audit process — including cross-trained personnel, audit checklists and self-audits — can help ensure a successful outcome.

The top seven issues found with PSM compliance:

1. Outdated process safety information

This includes:

• Safety relief system
• Ammonia inventory
• Ventilation calculations
• “Field verified” piping and instrumentation drawings (P&IDs)

Many times, facilities have made changes to the ammonia system without updating this documentation.

2. Previous Process Hazard Analysis (PHA) issues

Outstanding PHA recommendations that have not been addressed or properly closed out

3. Vague Standard Operating Procedures (SOPs)

Those that are generic in nature, not equipment specific and have not been reviewed/certified annually as required by the OSHA Standard

4. Improper Management of Change (MOC) documentation

Too often, an MOC is completed after the equipment has been installed and is operational. Ensure that MOCs are fully completed and signed off by the authorizing personnel before startup of the equipment. Similarly, MOCs are many times forgotten when completing changes to Operating procedures, Elements, etc. MOCs are required for any change affecting how you do something (i.e., adding steps to the start-up process of a piece of equipment).

5. Lack of proper PSM training

PSM requires that personnel involved with the operation and maintenance of the ammonia system receive initial training and refresher training every three years.

6. Gaps in audit frequency

This refers to audits that have not been conducted every three years as required by the PSM Standard or the action items that were generated from the previous audit that have not been closed out in time for the next audit cycle.

7. Improper or unorganized documentation

In preparation for the audit, ensure all of your written documentation is up to date and filed in a format that is easily accessible to the auditor. The auditor will need to read and review a large amount of written procedures and guidelines. It’s best to place these documents in an office or conference room for the auditor to work from. This will also provide an area where the auditor can work privately and conduct employee interviews.

Three steps for a successful audit:

1. Assemble an Audit Team

Members of the audit team should be employees and/or contractors with experience and responsibilities in the following areas:

• PSM/RM coordinator/manager
• Refrigeration supervisor/technician
• Facility environmental, health and safety manager
• Facility engineer

2. Build an Audit Checklist

The current ammonia industry audit checklist was developed by IIAR in 2013 and combines the OSHA and EPA audit requirements into one complete audit. This checklist is available through the International Institute of Ammonia Refrigeration (IIAR).

3. Understand the Audit Process

The compliance audit should be a detailed examination of the effectiveness of your PSM program. The audit will review these areas:

• Written PSM program elements and all required documentation
• Ammonia system operating and maintenance procedures
• Observations of on-site conditions
• Kick-off meeting with the auditor to review agenda
• Interviews with key employees and contractors (if applicable)
• Post-audit meeting to review findings

The team leader is responsible for reviewing each item on the checklist with the team and explaining what criteria is acceptable for full compliance. Team members should have input on each item and determine if it is in compliance – this auditing can be streamlined online, too. If the item is not in full compliance, the audit team must establish recommendations to achieve full compliance. All recommendations must be corrected promptly.

If you’d like to learn more about improving your PSM audit process, email me at foodforthought@stellar.net.