Maximizing the Benefits of Compliance Audits
By Cheryl Garcia, Process Safety Technical Consultant
When you hear that it’s time for a compliance audit of your Process Safety Management (PSM) system or Risk Management Program (RMP), what’s your initial reaction? It’s most likely something along the lines of, “Again? Didn’t we just do that?” or “This is going to take time that I could be spending on real work.”
You’re not alone. Audits are often viewed as a burdensome necessary evil – a box to tick before getting back to what feel like more important tasks. However, with the right approach, mindset, preparation, and a willingness to engage, these audits can become powerful tools for improvement used for your site and professional benefit.
Compliance Audits Can Be Your Ally
Think of external auditors not as critics, but as fresh eyes dedicated to strengthening your process safety programs. When an external auditor comes in to review your documentation, interview employees, and do field walks, they’re actively searching for areas where your process safety and risk management programs can be improved. Although it can be uncomfortable to have an “outsider” critique something that you’ve spent significant time and energy developing and implementing, the end result – the audit report and findings – can reveal gaps in processes or procedures and pinpoint opportunities for improvement that might be difficult for internal personnel or teams to uncover. Being open to the auditors’ feedback – both positive and critical – will ultimately help you strengthen your process safety and risk management programs.
How to Score Quick Wins During an Audit
Take advantage of the opportunity to learn from the experts – the auditors – who are on-site and focused on your facility or process. They can offer guidance for filling in gaps in the PSM or RMP documentation or implementation, and they’ll likely have templates, tools, and tips that you can quickly put to use in your own facility. Plus, the audit findings and report can serve as justification when asking management for additional resources or funding to strengthen your process safety and risk management programs.
Another benefit is that the compliance audit can identify best practices in your area that could be implemented across the company, making your facility a flagship example of process safety excellence.
Be Prepared and Be Honest
To make the most of the compliance audit, you should begin preparing well before the audit dates – typically 4-6 months prior. In addition to gathering documentation, you’ll want to identify team members and begin preparing them for the audit. To build a well-rounded and robust team, you should include employees from all areas that are directly involved with the process being audited, including operations, maintenance, and management.
When choosing team members, keep in mind that you want participants who will be realistic with the auditors about how well your processes and procedures work, where their shortcomings might be, and obstacles to their implementation. This openness will help the auditors provide valuable, actionable feedback.
Compliance Is the Floor, Not the Ceiling
Keep in mind that mere compliance with the standard is not the ultimate goal. The primary reason for implementing a process safety management system or risk management program is to ensure the safety of the environment, workers, and the community. The risk of not following the audit schedule or not being compliant isn’t the monetary fine that OSHA or the EPA might hand down. The real risk is an unaddressed hazard that could cause a major incident or accident. The purpose of the PSM and RMP audits is to help identify these risks and ensure processes and procedures are in place to prevent or mitigate them.
In other words, compliance is the floor, not the ceiling. Your goal when implementing a process safety management system or risk management program should be not just to meet, but to exceed the compliance requirements. Hargrove’s Process Safety Team can evaluate the effectiveness of your process safety and risk management programs. To get started, request a consultation now.
