PSM AUDITS UNMASK MYRIAD MISTAKES This final part in our series covers a broad variety of commonly found issues

摘要

PROCESS SAFETY management(PSM)audits serve two main functions:to provide feedback on process safety program implementation and effectiveness to identify potential opportunities for improved performance;and to verify compliance with process safety regulations such as the 29 CFR 1910.119 Process Safety Management(PSM)standard of the U.S.Occupational Safety and Health Administration(OSHA)and the 40 CFR 68 Risk Management Program(RMP)rule of the U.S.Environmental Protection Agency(EPA)1,2.A facility with a process covered by these regulations must conduct compliance audits every three years.Previous parts of this series covered some common issues observed in PSM compliance audits related to operating/safe-limits tables 3,operating practices 4 and mechanical integrity 5.Now,we will look at findings in the elements of process safety information(PSI)process hazard analysis(PHA)management of change(MOC)and pre-startup safety review(PSSR)contractors;incident investigation and emergency planning and response(EPR)compliance audits;and employee participation(EP)and trade secrets.(Industry guidance documents 2,6 provide additional information about PSM element requirements.)