Process Safety Management Boot Camp Training

Oil & Gas Skills (OGS)

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Module 24
Element 19 - Auditing

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What is an audit?

 An audit is a systematic and independent examination of an organization’s PSM elements to

ascertain that these have been developed, implemented and maintained such that these PSM
requirements and PSM framework expectations are met

 An audit may be classified as internal or external, depending on the interrelationships among

participants. Internal audits are performed by employees of the company’s organization

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Typical O&G company HSE management system

Policy & Strategic Objectives

Organisation, Resources & Competence

Risk Evaluation & Management

Leadership Corrective Actions

& Commitment Planning Standards & Procedures

Implementation & Monitoring

Audit

Management Review Continuous improvement

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Texas City Refinery - PSM deficiencies

 No effective system to audit the process safety

Leadership & Commitment
performance at BP’s U.S. refineries
 Inadequate inspections by the Regulator (OSHA)
Policy & Strategic Objectives

Organisation, Resources & Competence

Risk Evaluation & Management

 Regular review and audit of compliance is vital to
Planning Standards & Procedures ensure that process safety performance continues to
meet the defined targets
Implementation & Monitoring

Audit

Management Review

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Monitoring mechanisms

 Auditing complements other control and monitoring activities in elements such as management
review, metrics, and inspection work activities that are part of the asset integrity, conduct of
operations elements and other PSM elements
 The audits element comprises a system for scheduling, staffing, effectively performing, and
documenting periodic evaluations of all RBPS elements, as well as providing systems for
managing the resolution of findings and corrective actions generated by the audits

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Auditing – expectations (1)

 Audit criteria are defined to provide a consistent basis for audit and a consistent basis for
development of the audit opinion
 A routine internal (2nd party) audit programme is in place with audits carried out by personnel
from the organisation
 A routine external (3rd party) audit programme is in place with audits carried out by personnel
independent of the organisation. The external audit assesses and provides an independent
opinion on compliance
 Audits are conducted by trained, competent multidisciplinary teams, including HSE and
process safety professionals and personnel with operational and technical expertise
 The frequency and scope of the audits will reflect the complexity of the operation, the level of
risk and previous EI PSM framework compliance history
 Audit opinion and findings are reviewed with specified levels of management

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Auditing – expectations (2)

 Documentation and tracking of actions. Necessary interventions to correct identified issues,

non-compliances and deviations in performance, beyond defined tolerance levels, are identified,
appropriately prioritised, scheduled and tracked to completion
 The effectiveness of the audit arrangements is periodically reviewed and the findings are used to
make improvements

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ISRSTM – example of external auditing system

 ISRS 9 describes best practice in safety and sustainability management

 In addition, ISRS includes the requirements for major international standards certification to help
guide organisations in building integrated systems to meet certification requirements. E.g.:
– ISO 45001:2018 Occupational Health & Safety Management
– ISO 14001:2015 Environmental Management
– ISO 9001:2015 Quality Management
– ISO 55000:2014 Asset Management
– ISO 50001:2019 Energy Management
– OSHA 1910.119 - Process Safety Management
– Seveso III Directive - 2012/18/UE - Process Safety Management
 ISRS 9 describes “core” requirements which unpack and clarify the requirements the of ISO
standards to facilitate simpler and more effective integrated assessments

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References

 CCPS, “Guidelines for Auditing Process Safety Management Systems, 2nd Edition”, ISBN: 978-0-
470-28235-9, February 2011
 Energy Institute, “Guidance on meeting expectations of EI Process safety management
framework - Element 20: Audit, assurance, management review and intervention”, 1st edition,
July 2016

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