Risk Based

PROCESS SAFETY
MANAGEMENT -
Auditing
2 Days Training Course

Module 5 – Day 4 and 5

 Training Program

• Day 1:
o Module 1: PSM Introduction and Overview
• Day 2:
o Module 2: 4 Pillars of PSM and Pillar 1 & 2 Elements
• Day 3:
o Module 3: Pillar 3 and Module 4: Pillar 4 Elements
• Day 4 and 5:
o Module 5: Auditing RBPSM
• Day 6:
o Module 6: SIL and LOPA
• Day 7: Consolidation and Tests
• Day 8: Site visit
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 Main Objectives

After this two days course, you should understand:

ISO 19011 – Auditing Standard
• Audit Principles
• Audit Planning
• Conducting the Audit
• Reporting
• Planning a PSM audit
• Auditing techniques
• Writing PSM Audit reports
• Roles and responsibilities of personnel involved

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 Course Objectives

You will learn about

• why RBPSM Auditing is required

• Scheduling and required resources to implement a PSM

Audit

• Examples of PSM Audits

• Exercises

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 ISO 19011 - Auditing Std
• Auditor Evaluation Process • Impartiality
• Competence Requirements • Confidentiality
• Evaluate competence • Fair and truthful
• Maintain and improve • Evidence-based
competence

7. Auditor 4. Principles
Competence

5. Audit
Activities
Program
6. Audit
• Initiate activities
• Plan Audit • Program Objectives
• Conduct Audit • Establish Program
• Prepare and Distribute • Implement Program
Report • Monitor and Review
• Follow up Program
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 Auditing - Types
First party audit : Conducted by, or on behalf of, the
organization itself for management review and other internal
purposes
Second party audit : Audits of contractors/suppliers
undertaken by or on behalf of a purchasing organization.
This may include the assessment of companies or divisions
supplying goods or services to others within the same
group.
Third party audits: Audits of organisations undertaken by
an independent certification body or registrar or similar third
party organization.
Limited scope audits: Any request of client to audit part of
standard, specific problem or a specific area. Assurance
Audits, Follow up Audits, Systems Audits, Pre- Audits.
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 Terms and Definitions

 Internal audits - first-party audits, are conducted by, or on

behalf of, the organization itself for management review
and other internal purposes.
 External audits - second- and third-party audits.
 Audit criteria - Set of policies, procedures or
requirements.
 Audit evidence - Records, statements of fact or other
information, which are relevant to the audit criteria and
verifiable . Audit evidence may be qualitative or
quantitative.
• Audit findings - Audit findings can indicate either
conformity or nonconformity with audit criteria or
opportunities for improvement.
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 Terms and Definitions

• Audit client / Auditee - Organization or person requesting

an audit.
• Auditor - Person with the competence to conduct an audit.
• Technical expert - Person who provides specific knowledge
or expertise to the audit team.
 Audit programme - Set of one or more audits planned for a
specific time frame and directed towards a specific purpose.
 Audit plan - Description of the activities and arrangements
for an audit.
• Audit scope - Extent and boundaries of an audit. The audit
scope generally includes a description of the physical
locations, organizational units, activities and processes, as
well as the time period covered.
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 Audit Quality
The quality of the audit is directly dependent on the following
factors:
• Using competent personnel.
• Using a standardised audit protocol/questionnaire.
• Obtaining answers to audit questions from people who are most
knowledgeable about what is being assessed.
• Utilise techniques to verify information (interviews, document
verification, physical observation, etc.)
• Sample sizes should provide confidence in the audit results.
• Audit results must be documented accurately.
• The report should provide management with feedback on what is being
done properly as well as where to and how to improve.
• The audit result should be an accurate reflection of the system
implemented.

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 Audit Program

• An Organisation may establish more than one audit program

• The organisation’s top management should grant the authority for
managing the audit program
• The audit program should be:
o Established, implemented, monitored, reviewed and be
improved continuously
o Managed and coordinated with sufficient resources assigned to
the program.

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 Audit Program

Objectives should be established for an audit programme, to direct the

planning and conduct of audits. These objectives should consider:
• management priorities,
• commercial intentions,
• management system requirements,
• statutory, regulatory and contractual requirements,
• need for supplier evaluation,
• customer requirements,
• needs of other interested parties, and
• risks to the organization.

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 Audit Program
• An audit schedule should be prepared for carrying out internal
management system audits. The audits should cover the entire
operation which is subject to the management system, and assess
conformity.
• The frequency and coverage of management system audits should
be related to following:
– the risks associated with the failure of the various elements of the
management system,
– available data on the performance of the management system,
– the output from management reviews, and
– the extent to which the management system or the environment in which it
operates are subject to change.

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 Audit Activities
• Initiate the Audit
– Establish contact with the client / auditee
– Confirm the audit scope and feasibility
• Plan the Audit
– Establish the audit team
– Develop audit plan
– Prepare audit work documents
• Conduct the Audit
– Opening meeting
– Conduct document review
– Communicate during the audit
– Obtain physical evidence
– Record audit findings
– Prepare audit conclusions
– Present audit findings (Closing presentation)
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 Audit Activities

• Reporting
– Prepare the audit report
– Distribute the audit report
– Follow up on audit

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 Audit Plan
An Audit Plan should contain the following:

• Auditee
• Date of audit
• Scope of audit
• Auditors (indicating lead auditor)
• Schedule of activities illustrating the following:
o Activities per day and time of day
o Auditor(s) arrival
o Induction / Orientation Training
o Opening Meeting
o Planning / Confirmation session
o Systems audit (documentation) per element
o Field verification / compliance audits indicating specific areas of the site
o Communication sessions or feedback meetings
o Auditor consolidations (daily / final)
o Feedback / Closing Meeting
o ** All above activities should indicate auditor and auditee involvement
 Conducting the Audit

Gathering Evidence:
Field audit : The management system audit requires examining, on a sample basis,
audit evidence to support conclusions on compliance with the relevant standards,
and the effectiveness of the system.
The purpose of sampling is to focus audit efforts on the areas of potential risk of
non-compliance

Sample selection: While there are no hard fast rules around the necessary
sampling intensity, a sample size of 10% to 20% is generally appropriate

Collecting and verifying information: Only information that is verifiable may be

audit evidence. Audit evidence should be recorded. The sources of information
chosen may vary according to the scope and complexity of the audit

Verifying evidence : record reviews of critical program activities, interviews and

perception surveys of employees conducted at random and at all levels and for all
areas and shifts, and assessing the level of conditions within the worksite.
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 Conducting the Audit

Interviews:
Interviews are one of the important means of collecting information and
should be carried out in a manner adapted to the situation.
Consider the following:
• Interviews should be held with persons from appropriate levels.
• Interviews should be conducted during normal working hours and,
where practical, at the normal workplace .
• Put the Interviewee at ease.
• The reason for the interview and any note taking should be
explained.
• Interviews can be initiated by asking the persons to describe their
work.
• Questions that bias the answers should be avoided.
• The results from the interview should be summarized and reviewed.
• The interviewed persons should be thanked for their participation.
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 Conducting the Audit

Audit Findings:
• Audit evidence should be evaluated against the audit criteria to
generate the audit findings.
• Findings can indicate either conformity or non-conformity.
• Audit findings can identify an opportunity for improvement.
• Non-conformities and their supporting audit evidence should be
recorded.
• Non-conformities may be graded (Observation/Minor/ Major)
• In grading the non-compliance, the auditor should consider:
o The legal requirements;
o The magnitude of the event(s) or condition(s) leading to the non-
compliance;
o Standard requirements;
o The severity of the consequences (potential or real); and
o The frequency of occurrence
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 Audit Report

A typical SHEQ System Audit Report contains the

following:
• Cover page identifying the organisation audited, the date of the audit, the
organisation conducting the audit and auditors.
• The objectives and scope of the audit.
• A description of the criteria against which the site’s SHEQ systems were audited.
• The names and titles of auditee’s personnel participating in the audit.
• A summary of the audit process.
• Significant noteworthy efforts.
• Significant suggestions for improvement to ensure conformance to the audit
criteria used.
• Summary of findings and score (if applicable).
• A completed audit questionnaire or document reflecting all questions and audit
comments.
• Other report requirements (photo reports, perception surveys, etc).
 Audit Conclusion

The Audit Team will make a preliminary assessment of the degree of

compliance/non-compliance. In assessing compliance, the team will
review the evidence collected and conclude on whether or not the
auditee complied with the applicable requirements as per the audit
scope.

Audit conclusions address issues such as:

• Extent of conformity of the management system.
• Effective implementation, maintenance and improvement of the
management system, and
• Capability of the management review process to ensure the
continuing suitability, adequacy, effectiveness and improvement of
the management system.

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 Reasons why audits fail

Audits fail because of:

• Inadequate Scope
• Failure to highlight serious issues results in a false sense of
security to the client.
• Undue focus on scores, failure to focus on the areas for
improvement.
• Inadequate Auditor skill / training.
• Over complex audit protocols.
• No support from top management.
• Biased Auditors.
• Subjectivity during audits / no objective evidence findings.
• Inspection focus and not auditing – failure to follow audit trail.
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 Group discuss 1

Scenario:
• Company ABC, a chemical processing plant, has a
scheduled internal audit. The company provided the incident
register for perusal to the auditor. A series of ammonia leaks
registered. The last incident was 6 months ago. The following
controls were implemented 3 months ago:
– SIL2 rated pipeline pressure measurement systems and instruments,
monitored from the central control room
– Operating pressures were decreased from 450kPa to 350kPa
– Fixed gas monitors and alarms along the pipeline and tanks
• How does the auditor measure the effectiveness of the
controls?

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 Group Discussion 2

Answer the following regarding Audit Principles:

• You are the Lead Auditor planning the Audit at your company. The Engineer of
the Tank Farm was included in the audit team. Would you assign him to audit
the Tank Farm area?
• The pipelines from the Tank Farm to the Production Plant are seriously
corroded. The Maintenance Manager and various Maintenance Personnel
explained in detail how the pipes are being inspected on a monthly basis. Do
you accept the answer?
• The new design of the planned scrubber systems in the Tank Farm was
presented to you during the audit by the Engineer. The documentation clearly
indicated the cost of the project which was classified confidential since it was
not approved yet. During your interview with the Medical Doctor at the clinic,
who treated employees for toxic gas exposure, he asks if you knew the cost of
the project. Do you disclose the information to him?

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 Group Discussion 3

Interviews:
1. A maintenance technician is busy performing a sensor change on one of
the gas lines in the plant. He did not isolate the gas energy since the
line is not used during that time of the day, but only during night shift.
The possibility exist that there might be gas in the pipe. The Safety
Manager and Plant Engineer is accompanying you.
– How would you handle the situation and
– What questions would you ask to who?
2. During an interview with the controller in the control room, you realise
that the limits on the pressure monitoring system has not been set
accurately. The Shift Manager and a Safety Officer
accompanied you to the control room.
– What questions do you ask the controller
– Do you approach the Shift Manager and what would you
ask him?
3. How would you test if the people in the control room are f amiliar with the
Emergency Response Plan for a gas leak? (Classroom discuss)
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 RBPSM AUDIT

RBPSM AUDIT

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 Process Safety – Why Audit

WHAT IS PROCESS SAFETY:

A systematic approach to major incident hazard management.

WHY PROCESS SAFETY AUDITING?

• evaluates the effectiveness and efficiency of the
organisation, obtaining objective evidence that the existing
Process Safety System requirements have been met; and

• is also a process whereby organisations can review and

continuously evaluate the effectiveness of their HS and E
management system.
• Why audit - ensure that facilities are well designed, safely
operated and properly maintained.

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 RBPSM AUDIT
Over view of PSM Auditing (Compliance Audit)

1- Employers shall certify that they have evaluated

compliance with the provision of this section, at least
every three yeas to verify that the procedures and
practices developed under the standard are adequate and
are being followed

2- the compliance audit shall be conducted by at least

one person knowledgeable in the process

3- a report of the findings of the audit shall be developed

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 RBPSM AUDIT
4- the employer shall promptly determine and document
an appropriate response to each of the findings of the
compliance audit and document that deficiencies have
been corrected.

5- employer shall retain the two most recent compliance

audit report

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 RBPSM AUDIT
The audit Is to include an evaluation of the design and
effectiveness of the process safety management system
and a field inspection of the safety and health condition
and practices to verify that the employer’s system are
effectively implemented.

The essential elements of an audit program include:

planning,
staffing,
conducting the audit,
evaluation and corrective action,
follow up and documentation.
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 RBPSM AUDIT

Planning

Planning in advance is essential to the success of the auditing

process. Each employer needs to establish the format, staffing,
scheduling and verification methods prior to conducting the audit.
The format should be designed to provide the lead auditor with a
procedure or checklist which details the requirements of each
section of the standard. The names of the audit team members
should be listed as part of the format as well. The checklist, if
properly designed, could serve as the verification sheet which
provides the auditor with the necessary information to expedite the
review and assure that no requirements of the standard are
omitted. This verification sheet format could also identify those
elements that will require evaluation or a response to correct
deficiencies. This sheet could also be used for developing the
follow-up and documentation requirements. 30
 RBPSM AUDIT

Staffing
The selection of effective audit team members is critical to the
success of the program. Team members should be chosen for their
experience, knowledge, and training and should be familiar with the
processes and with auditing techniques, practices and procedures.
The size of the team will vary depending on the size and complexity
of the process under consideration. For a large, complex, highly
instrumented plant, it may be desirable to have team members with
expertise in process engineering and design, process chemistry,
instrumentation and computer controls, electrical hazards and
classifications, safety and health disciplines, maintenance,
emergency preparedness, warehousing or shipping, and process
safety auditing. The team may use part-time members to provide for
the depth of expertise required as well as for what is actually done
or followed, compared to what is written.
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 RBPSM AUDIT

Conducting the Audit

An effective audit includes a review of the relevant documentation and process

safety information, inspection of the physical facilities, and interviews with all
levels of plant personnel. Utilizing the audit procedure and checklist developed
in the preplanning stage, the audit team can systematically analyze
compliance with the provisions of the standard and any other corporate
policies that are relevant. For example, the audit team will review all aspects of
the training program as part of the overall audit. The team will review the
written training program for adequacy of content, frequency of training,
effectiveness of training in terms of its goals and objectives as well as to how it
fits into meeting the standard's requirements, documentation, etc. Through
interviews, the team can determine the employee's knowledge and awareness
of the safety procedures, duties, rules, emergency response assignments, etc.
During the inspection, the team can observe actual practices such as safety
and health policies, procedures, and work authorization practices. This
approach enables the team to identify deficiencies and determine where
corrective actions or improvements are necessary. 32
 RBPSM AUDIT

Evaluation

An audit is a technique used to gather sufficient facts and information,

including statistical information, to verify compliance with standards.
Auditors should select as part of their preplanning a sample size sufficient
to give a degree of confidence that the audit reflects the level of compliance
with the standard. The audit team, through this systematic analysis, should
document areas which require corrective action as well as those areas
where the process safety management system is effective and working in
an effective manner. This provides a record of the audit procedures and
findings, and serves as a baseline of operation data for future audits. It will
assist future auditors in determining changes or trends from previous
audits.

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 RBPSM AUDIT
Corrective Action

Corrective action is one of the most important parts of the audit. It

includes not only addressing the identified deficiencies, but also planning,
follow-up, and documentation. The corrective action process normally
begins with a management review of the audit findings. The purpose of
this review is to determine what actions are appropriate, and to establish
priorities, timetables, resource allocations and requirements and
responsibilities. In some cases, corrective action may involve a simple
change in procedure or minor maintenance effort to remedy the concern.
Management of change procedures need to be used, as appropriate,
even for what may seem to be a minor change. Many of the deficiencies
can be acted on promptly, while some may require engineering studies or
in-depth review of actual procedures and practices. There may be
instances where no action is necessary and this is a valid response to an
audit finding. All actions taken, including an explanation where no action is
taken on a finding, needs to be documented as to what was done and
why. 34
 RBPSM AUDIT

Follow-up & Documentation

It is important to assure that each deficiency identified is addressed, the

corrective action to be taken noted, and the audit person or team
responsible be properly documented by the employer. To control the
corrective action process, the employer should consider the use of a
tracking system. This tracking system might include periodic status reports
shared with affected levels of management, specific reports such as
completion of an engineering study, and a final implementation report to
provide closure for audit findings that have been through management of
change, if appropriate, and then shared with affected employees and
management. This type of tracking system provides the employer with the
status of the corrective action.

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 RBPSM AUDIT

MANAGEMENT OF PSM AUDITS

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RBPSM AUDIT

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RBPSM AUDIT

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 RBPSM AUDIT
Pre-Audit Activities

Audit Scope
The audit scope refers to the chemical process facility boundaries. Within the
boundary, the PSM subject areas will be verified for implementation. PSM audits
can vary considerably in scope. Defining the audit scope is critical and requires that
it is clearly communicated to management, since they bear ultimate responsibility
for any deficiencies in implementation. Setting the scope also helps focus the
auditor‟s attention; it is also important for auditors to be consistent and for them to
prevent misleading interpretations (which can easily arise outside of the
implementation scope).
A number of factors need to be evaluated when defining the audit scope:
 Company policies
 Regulatory requirements
 Resource limitations
 Time availability
 The size and the complexity of the process
 Risk of the process(es)
The scope of the audit may cover the overall facility by one comprehensive audit or
several segregated audits over a defined period.
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 RBPSM AUDIT
Audit Frequency

The PSM audit frequency depends on several factors, such as:

1. Complexity and/or risk of the process. This is the most significant factor in
determining the frequency of the audit. The more complex or the higher risk
(consequence of occurrences multiplied by the likelihood) the operation is, the
more frequent your audit should be.

2. Maturity Level of the PSM Program. The less established and immature the PSM
program, the more frequent your audit should be.

3. Previous PSM Audit Results. If results from previous audits indicate large gaps in
the implementation then the audit frequency should be increased.

4. Incident History. If accidents and near misses are experienced often, then the
frequency should be increased.

5. Corporate Policy. Most corporations have internal policies that predefine audit
frequency. 40
RBPSM AUDIT

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 RBPSM AUDIT
Audit Team Members Training

The PSM audit coordinator does or coordinates the detailed audit training for new
auditors and refresher training for current auditors. Detailed PSM audit training
should include:

 Audit types, cost, and benefits

 The purpose, scope and current status of the Process Safety Management (PSM)
program in place at the site
 Site PSM Implementation organization structure
 PSM audit purpose
 PSM audit organization structure and how it fits with the site PSM implementation
structure.
 An overview of the site PSM audit protocol and scope of work
 Roles and responsibilities of the auditors
 Tips on carrying out audit activities such as interviewing, field observations, and
notes

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 RBPSM AUDIT
Refresher training will consist of only one-to-two hours and should cover:

 A summary of the site PSM implementation and audit structures, current status,
and scope of work
 Changes in PSM implementation and PSM audit programs since the last audit
 A review of auditor‟s roles, responsibilities and activities.

Once training is given to all the auditors a brief meeting should be held among all the
auditors to cover:

 Team and element assignments

 Handing out audit preparation information on each element
 A review of the audit schedule
 A review of roles and responsibilities at each stage
 Answering any questions

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 RBPSM AUDIT
Planning and Scheduling

Planning starts with the assignment of the PSM audit sponsor. This should occur at
least three months prior to the audit. It is preferred to provide such training a year in
advance to allow for preparation and communication to take place. The pre-audit
schedule includes team appointment, team training, communications, and audit
preparation status reviews. Compliance audits typically take between one-to-two
week of data gathering activities and meetings. Activities during the audit period
includes the audit of each individual PSM element, individual element audit review
meeting with the element administrator, draft report issuance, and the overall
opening and closing review meetings with senior management. Time should be
allocated after the audit for the preparation of the audit final report. The preparation
of the final audit should include alterations required once the draft audit report is
returned from the site‟s PSM coordinator.
It is important to periodically update all personnel involved in the audit on the current
preparation status so they may prepare their data in conjunction.

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 RBPSM AUDIT

Information and Data Collection

The information and data required by the auditors are:

 PSM audit schedule.
 Individual PSM documentation & PSM element interpretation and guidelines.
 PSM audit worksheets.
 PSM audit rating matrix.
 The last audit result summary.
 Summary of the three year PSM management plan.
 Current year PSM management action plan which includes resolution of
recommendations from previous audits.
 Annual incident analysis
 PSM progress verification records.
 PSM element related correspondence.
 PSM management/sponsor‟s telephone listings.
 Audit critique forms (audit team and interviewees).

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RBPSM AUDIT

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 RBPSM AUDIT

Opening Meeting with Senior Management

An opening meeting with Senior Management is required to begin the

formal audit process. The duration of this presentation should not be more
than half an hour. The purpose of the presentation is to explain the audit
objective, scope, and methodology of the audit. The members of the audit
teams are introduced to senior and middle management. This is a two-way
discussion, which can clarify any final points concerning the objective and
scope of the audit. The audit schedule summary is briefly reviewed and
reconfirmed.

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 RBPSM AUDIT

Site Documentation and Implementation Review

Audit teams review the documentation developed by the site to measure

compliance. The documentation review may occur prior to the implementation
review. Results of this phase of the audit are recorded separately.

Before starting the element implementation review, the first interview for each
element should be with the element administrator. The element administrator
should begin by explaining how the element is set up and applied at the site.
Points to be discussed further should be noted during the narrative, with a
natural follow on to the detailed questions.

The audit team then makes onsite visits and review documents generated by the
application of the element management system for each PSM element.
Appropriate personnel at all levels within the organization are met and
interviewed in order to obtain a balanced view of how things measure. These
observations may also identify areas, which should be investigated further.
Questions should be asked based on the actual documentation found, on-site
observations, and the interviews themselves. 48
 RBPSM AUDIT
Data Evaluation

 When the element audit is complete, but before data is evaluated, the audit team
holds a review meeting with the site PSM element administrator. The meeting
should:
1. Confirm data accuracy.
2. Highlight key findings.
3. Correct any mistakes or misunderstandings.
4. Identify areas of disagreement.

 The element team leader evaluates the data with team members. They need to:
1. Discuss individual findings with the aim of preparing a consistent final checklist.
2. Review all findings and working paper comments, to ensure fieldwork
completeness.
3. Discuss the areas of disagreement with the element administrator and reach a
team position.
4. Complete all sections of the checklist including the summary page and ratings.
5. Share findings with other teams to ensure feedback from interacting elements
does not conflict.
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 RBPSM AUDIT

Audit teams should meet with the site PSM coordinator to:

1. Discuss team findings for each element and align team feedback with the aim of
preparing consistent final checklists for all elements.
2. Ensure that a common style and approach is adopted.
3. Resolve any disagreements on the audit findings.
As each element audit checklist is completed the team leader prepares the closing
presentation in consultation with his team and the site PSM coordinator.

Audit team leaders should meet with the PSM coordinator and PSM sponsor
in a final meeting to review the closing presentation to:
1. Check that all information is included so that no “surprises” are brought to light in
any subsequent report or discussions.
2. Confirm that the presentation accurately reflects the “tone” as well as correctness
of the strengths, findings, and observations.
3. Confirm that language used in the presentation conveys the right message to
management.
4. Ensure that all members agree with the content of presentation.
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 RBPSM AUDIT

Audit Critique

By the end of the audit period, the auditors, site element administrators,
and other personnel directly involved in the audit are recommended to
critique the audit process and identify areas for improvement. The critique
could be done through a brainstorming session or forms developed for this
purpose may be used. All critique forms, or minutes of the brainstorming
session, should be handed to and evaluated by the site PSM coordinator
with the objective of improving future audits. The audit critique should be
part of the feedback in the closing presentation.

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 RBPSM AUDIT
Closing Meeting with Senior Management

 The Lead PSM Auditor should make a formal presentation of audit findings and observations
to management. Summaries are prepared beforehand with similar findings grouped under
common headings.

Attendees for the closing presentation should include the site Manager (may even be a group
or affiliate president, if their office is present at the site), Senior Management, the PSM
sponsor, and the PSM coordinator. The closing presentation should cover the following:
1. Audit team membership.
2. Audit focus.
3. Current element rating compared to target and the last Audit rating.
4. Current strengths.
5. Areas for improvement and recurring observations from previous audits.
6. General conclusions and suggestions.
7. Audit critique summary.
8. An overall summary
9. Target date for issuance of final report.
General questions for clarification are answered. The PSM sponsor and/or senior
management should endorse the audit findings. Any comments from this presentation should
be documented by the lead PSM auditor and incorporated into the final report.
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RBPSM AUDIT

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 RBPSM AUDIT

Final PSM Audit Report

The report is intended to provide assistance to management. The results

need to be presented in a balanced and constructive manner highlighting
both proficiencies and deficiencies. The final report should include the
following:
 An executive summary indicating the key findings.
 An introduction highlighting the purpose, scope and overall report
content.
 Brief explanation of the methodology.
 Element-wise performance highlighting strengths and areas of non-
compliance. Documentation, implementation, and overall rating (if
applicable). Completed checklists used should be attached as a soft or
hard copy.
 A summary of progress made since the last audit.
 Audit critique recommendations to improve the next audit.

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 RBPSM AUDIT

The audit team members were originally selected for their knowledge and
experience and should have valuable suggestions to offer. However, these will be
„suggestions for consideration‟ or „observations‟ (as they are routinely called in
the USA) rather than findings and recommendations because:

 There may be legal implications if the report indicates that specific

improvements must be carried out and subsequently they are not.
 It may be possible that the recommendation is impractical, or may not achieve
the desired effect or may have an undesirable effect in other areas.
 There may be a better alternative not considered by the assessors.
 The company may have higher priority items, or financial constraints.
 There may be resistance to being told what to do, even though well meant.

In other words, developing recommendations for resolving findings and

observations is typically outside the audit teams‟ area of responsibility. Once the
company/site management receives the findings and observations and concurs, it
is management‟ responsibility to develop specific recommendations and plans for
resolving the deficiencies or addressing the observations.
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 RBPSM AUDIT

Follow-Up Activities

The audit report becomes part of the ongoing cycle of PSM implementation
and future audits under the responsibility of the PSM coordinator, with
follow up included as part of the progress towards an effective PSM
management program.
The audit findings are translated into actions with the following suggested
activities and responsibilities:
 Audit findings and observations are prioritized by the site PSM element
administrators in consultation with operations department managers
and other affected managers.
 An appropriate action plan (follow up and target completion dates) is
defined within two-three months of the audit. his is the responsibility of the
site PSM element administrators in consultation with operations department
managers and other affected managers.
 Agreed action is taken by the site element administrators.
 Periodic follow up reports summarizing action plan status are issued by
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 RBPSM AUDIT

OPERATING PROCEDURES

IDENTIFICATION OF MANAGEMENT SYSTEM

1. Identify who is responsible for developing written procedures that address the
following:

a. steps for each operating phase

b. operating limits
c. safety and health considerations
d. safety systems and their functions

2. Identify mechanisms in place to ensure that operating procedures are readily

accessible (e.g., location for a controlled copy specified, other document control
system features).

3. Describe the system in place to ensure that operating procedures are reviewed,
updated when necessary, and annually certified.
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4. Determine how the requirements of the following safe work practices are
communicated:

a. hazardous energy lockout/tagout

b. confined space entry
c. opening process piping or equipment
d. control over entrance into a facility by support personnel
5. Determine who is responsible for annually certifying procedures.
6. Identify written specifications (e.g., criteria) for procedures format and/or content.
7. Identify written qualifications (e.g., prerequisites) for procedure writers.
8. Determine how development of new procedures is initiated.
9. Describe the review and approval process for new and/or revised procedures.

CONFIRMATION AND VERIFICATION ACTIVITIES (GENERAL)

1. Review written procedures and other documents (e.g., operating manuals,
emergency management plans) to confirm that the following items are addressed:
a. Steps for each operating phase

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i. initial startup (for units started up after 8/26/92)

ii. normal operation
iii. emergency shutdown — must include conditions that require emergency
shutdown and assignment of shutdown responsibilities to qualified operators
iv. emergency operations
v. normal shutdown
vi. startup following a turnaround or after an emergency shutdown
b. Operating limits
i. consequences of deviating from limits
ii. steps required to avoid or correct deviations
c. Safety and health considerations for chemicals used in the process
i. properties and hazards
ii. necessary precautions to prevent exposure (e.g., administrative controls,
personnel protective equipment [PPE])

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iii. actions to take in response to an exposure
iv. quality control for raw materials
v. control of inventory levels
vi. any special or unique hazards
d. Safety systems and their functions
i. description of the purpose (e.g., design intent)
ii. how they are activated
iii. special or unique limitations (e.g., design-basis limitations)

2. Interview employees who work in and maintain the process to confirm that
operating procedures are readily accessible and are in all designated locations

3. Review written procedures and other documents (e.g., operating manuals) to

confirm that: [29 CFR 1910.119(f)(3)]
a. procedures are updated for changes
b. procedures are certified annually

4. Through document review, field observations, and/or interviews, verify that the
following work practices are in place and are being followed (e.g., signs in place,
permits posted, logs maitained
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RBPSM AUDIT

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KEY PERFORMANCE INDICATORS AND TARGETS’s SAMPLES

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 Group Exercise 1

With reference to the following information, compile an

audit plan:
• A limited scope RBPSM audit is planned from 17 – 19 March 2014 at AB
Chemical Processors.
• The RBPSM System is to be audited on the following elements:
– The elements of the first pillar of RBPSM
• Two auditors will be conducting the Audit A and B.
• Auditor A is the lead auditor.

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 Exercise - Audit Plan
Company:
Auditors:
Scope:
Audit Date:

Day 1:
Time Activity Detail Area Auditee Auditor

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 Group Exercise 2

Conducting the Audit:

1. It is vitally important that a standardised audit protocol be developed
and used for auditing purposes. Why is this important?
2. What type of questions would you include in the RBPSM audit protocol
for the following elements (give questions for both system /
documentation and compliance / verification auditing):
– Asset Integrity and Reliability
– Training and Performance Assurance
– Emergency Management
3. What evidence would you accept as proof of
compliance with each of the given protocol
questions given above?

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 Group Exercise 3

Making findings:
Formulate findings for the following scenarios:
1. Critical control valve inspections are overdue by 3 months.
2. The training matrix include all training courses schedule and
completed by all employees. PSM is not on the list.
3. A new earthling system was installed on a 20,000 lt tank to prevent
static discharge during filling. The system also involves earthling of the
tanker trucks delivering the chemical. A certain flow rate was prescribed
to reduce static build-up through the pipes. During the audit, you
observed that the operator did not earth the truck and pumped the
chemical at maximum flow rate (above the prescription).

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 Group Exercise 4

Document the audit approach you’ll take for:

Hazardous Chemical Company indicated the following
high risks identified in the latest MHI presented:

1. Hi volumes of ammonia in the tank farms with the main wind direction
blowing from the farm straight to the dense residential area of a newly
developed real estate.
2. Excessive dust build-up in the roof of the power generation plant where
a complex conveyor system is operating 24/7.
3. Age of the nitrogen pipelines. The pipelines are heavily corroded. The
plant is near the ocean and exposed to high humidity levels and salt in
the air.

Consider all relevant RBPSM elements applicable in all the cases above.

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 Practical

A Practical approach to RBPSM Auditing:

1. Determine the risks identified through risk assessments
(HAZOPS, MHI, PHA’s)
2. Assess what types of controls were implemented to control the
risks.
3. Follow the 4 pillars to determine whether the controls addressed
the applicable elements of RBPSM.
₋ First look at the documented evidence (procedures)
₋ Sample some records to proof the compliance
₋ Verify physically in the field if the controls are in place as per the
documents and records.
4. Measure continuous improvement of the implemented system
through revision of risks, controls and monitoring trends.

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End of Module 5
Thank you

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