Use of Internal PSM Audits by OSHA Inspectors
Before the OSHA PSM standard became official (May 1992), OSHA said that they would not use 3rd party or even first party (internal audits) of PSM against a company, but then they add “initially”. When asked by us what this meant, they said the first few years of implementation of PSM; this was to encourage covered sites to do PSM audits each year (not wait the maximum of 3 years). Then, one OSHA auditor in the southern USA did not follow this instruction from D.C. and got their hands slapped and the Director of OSHA apologized. About that time, I hired the Director of Enforcement at OSHA into our company (it was not PII at that time) to use him as an auditor (it turned out he was pretty good, but not as good as those who had been implementing PSM since the 1970s or earlier). He told us that after the grace period of a “few years” that OSHA would indeed use your own audits against you. This comment is why many folks starting creating one document called the “PSM Compliance Audit” and a second, more useful document called something else (to disguise it and so it would not be specifically under OSHA PSM Inspector’s domain), such as “process safety assessment report”, etc. The second report has much more specifics than the first; in fact, most of the time we do audits, this second report is an assessment against best practices (versus OSHA PSM which is definitely not best practices!!).
Outside of the USA, our audits results are in One, all inclusive report, and that audit is typically an assessment versus Best Practices and usually has a lot of focus on leadership and on human factors.
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