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 Compliance Audits




 

 
Basic Requirements

PSM and RMP contain the following periodic compliance audit requirements:

1.  Audit Requirements 

  • A Compliance Audit is completed at least every three years.
  • The Compliance Audit includes verification that the procedures and practices that have been developed to comply with the PSM and RM Program regulations are adequate and are being followed.
  • The Compliance Audit is conducted by at least one person or combination of people with knowledge of the fundamental process hazards for the ammonia refrigeration system.

2. Documentation Requirements

  • A written report of the findings of the audit is developed.
  • The facility promptly determines and documents an appropriate response to each of the findings of the Compliance Audit.
  • The facility documents that deficiencies have been corrected.
  • the facility certifies the Compliance Audit 
  • The two most recent Compliance Audit reports and documented responses to audit findings are retained by the facility.
  • The Compliance Audits are made available to employees and their designated representatives. 

3.  Training 

  • The personnel that staffs audit teams receive training in audit techniques. Such training covers the overall audit process, techniques for understanding and evaluating management systems, approaches to verifying implementation, and writing audit reports.

Federal Guidance

As far as substantive auditing checklists or guidance, most companies rely on the guidance supplied by OSHA and EPA for this purpose. Those guidance documents are:

  • OSHA CPL 2-2.45A CH-1 - Process Safety Management of Highly Hazardous Chemicals-- Compliance Guidelines and Enforcement Procedures (1994) (.HTML) 
  • Guidance for Auditing Risk Management Plans/Programs Under Clean Air Act Section 112(r) (August 1999) (.PDF, 855K)

Some companies have also developed more rigorous or more detailed ones to supplement the issues and questions posed by the regulations.

It is often desirable, though not required, that the audit be done by a third party. It may be valuable, however, to get the impartiality and different experience base of an outside consultant to at least participate in the audit. 

Other Guidance:

New Jersey Technical Assistance Program, Environmental Regulatory Compliance Self-Assessment for Small and Mid-Sized Industrial Facilities (link)
An evaluation checklist that, when completed, provides a thumbnail sketch of environmental compliance issues.

 

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