Auditing Elements: PHA, Compliance Audit, & Employee Participation (Part 5)

In this compliance audit blog series, we have decided to focus on each program element. If you plan to lead an audit, these lists will be instructional for you. But if you want to prepare for an upcoming audit, these lists will give you an idea of what to expect.

Process Hazard Analyses and Compliance Audits

Auditing PHAs and past compliance audits are similar in many ways. Here are some ways in which they may be audited:

• Confirm the reports from the activities are on file as required. PHAs are required to be kept for the life of the process and the two (2) most recent compliance audits reports should be on file (see Part 3 of this series).
• Confirm the activities are being completed on time (5 years for PHAs and 3 years for compliance audits).
• Confirm findings from these activities have written resolutions and are being completed in a timely manner.
• Field-verify a handful of completed recommendations from each activity. (E.g. If there was a recommendation to install a windsock on the southeast corner of the roof, verify the windsock has been installed.)
• Ask team members if these activities were thorough in their scope. One way to do this is to candidly ask team members what they remember from the PHA/audit.
• Ensure PHA reports meet the prescriptive requirements from the RMP, PSM, and CalARP regulations (using an approved methodology, addressing human factors, etc.).
• Ensure compliance audits reports have been certified.

Employee Participation

Since employee participation has so few prescriptive requirements, it is easy to audit. Here is how it may be audited:

• Determine if a written plan is in place for how employees will be involved in the program.
• Confirm if employees have participated in past PHA and compliance audits (the reports from these activities should include lists of participants).
• Ask an employee at the facility, who is not involved in the program, if they are aware of any chemical hazards at the facility. This is a good way to determine if they have been notified about the covered process and its associated PHA.

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This is Part 5 of a series on compliance audits. You can access previous blogs in this series below:

• Part 1: Compliance Audit Overview
• Part 2: Compliance Audit Team & Sessions
• Part 3: Compliance Audit Documentation
• Part 4: Auditing Elements: Process Safety Information