Keys to a Successful PSM Inspection

A PSM inspection^[1] is about as appealing as a colonoscopy; at least that’s what I’ve ascertained from the numerous clients who have called me, frantic for help and counsel.

For those who have been around the PSM/RMP world for any amount of time, we all recognize the stakes are high and the fines can be steep for the neglected and disorganized program. As such, facilities are right to be nervous when they are faced with a prospective inspection. However, this necessary part of business doesn’t have to give you an ulcer. Having participated in over 100 inspections in the last several years, with various agencies and inspectors, I’ve picked up a few things along the way. I share these with you now, in the hopes they will help lower your stress levels and aid a smooth inspection.

1) Inspectors are People too.

It is easy to see an inspector as the enemy. “They expect us to drop everything, and don’t seem to know (or care) we have a business to run.” “The documentation I have never seems to be good enough.” “I do one thing for one inspector, only to turn around and face a different inspector who wants it done differently.”

While I sympathize with such sentiments and statements, these are often unfounded attitudes. Furthermore, even if such attitudes were factually based (granted, sometimes they are), entering an inspection with this kind of perspective is about as useful as cussing out a cop.

Inspectors are people too. They are not the enemy. They have their own lives, their own families to feed, and with all sincerity, are simply trying to do their job well; just like you. I have yet to meet a regulator who is unreasonable when presented with thoughtful and well-supported logic in response to a potential violation or citation. In reality, local regulators genuinely want facilities in their jurisdiction to do well, and as such are open to meaningful conversation regarding the implementation of your program.

In order to participate in such conversation assumes, of course, you know what you are talking about and are engaged in your own program; which brings me to the next two points.

2) Know Your Program and its Weaknesses

Anyone who has worked with documentation knows that you can fake compliance. You can fill out a form; you can sign your name; you can even memorize the right things to say, but even mounds of documentation cannot cover a lack of competence.

The best way for an inspection to go smoothly is for you to know your program. For example, you should be able to answer the following questions off the top of your head:

• When was your last compliance audit? What is the status of the recommendations?
• When was your last PHA (Hazard Review)? What is the status of those recommendations?
• When is your anniversary date (5-Year RMP Submission)?
• When were your SOPs last certified?
• Describe your Mechanical Integrity program:
  • Non-destructive testing? Vibration Analysis? B-109 inspections? Daily, Weekly, Monthly inspections? Calibration of detection systems?
• How do you document / conduct training? Who gets trained on what?
• What was the most recent change to your system?

With all of this in mind, it is also important to know where your program is weak. Anticipate where an inspector might not be satisfied with your current documentation. It goes a long way if you can say, “We are aware of that and were discussing that very issue at our last compliance meeting.”

3) Honestly Engage

An inspection is a time for honesty, not deception or half-truths. If a regulator finds a legitimate flaw, weakness, or lack of documentation in your program, own up to the failure and be proactive. Ask for the inspector’s input. How have they seen it done at other facilities? Are there any resources they would recommend? Take the opportunity to engage with your inspector and learn from their experience.

Conclusion

An inspection can be nerve racking, but it doesn’t have to be. If you decide to honestly engage in the process, take the time to know your program, and respect your regulator with the dignity he/she deserves as a human being, an inspection can be, dare I say, enlightening and enjoyable.

---

^[1] The type of inspection the author has in mind for this article is a CUPA inspection. Generally speaking, these inspectors are more interested in helping facilities achieve long term compliance and less concerned with dealing out citations (though citations can be used as motivation to attain compliance). If OSHA or EPA has shown up at your door, their visit is most likely in response to an incident. In this case, the principles discussed here still apply, but citations should be expected.