Compliance Audit Overview (Part 1)
A Compliance Audit is a thermometer for PSM Programs.
This blog series will provide an overview of compliance audits as well as provide highlights for what auditors look for in each program element.
What is a Compliance Audit?
Facilities subject to the RMP, PSM, and CalARP regulations are required to conduct internal audits of their program. This activity is often confused with regulatory inspections, mechanical integrity audits, or even process hazard analyses, but the compliance audit is a distinct activity intended to provide a status report for the implementation of the RMP, PSM, and/or CalARP program.
Compliance audits are required to be performed every three (3) years. Unlike PHAs, compliance audits are not conducted initially. (This is logical given the activity is intended to audit the implementation of the program, and there is no history of implementation to audit when the program is first developed.)
Title 29 CFR §1910.119(o)(1)
Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
Surprisingly, the RMP, PSM, and CalARP regulations do not specify the exact date for when the first compliance audit must be conducted upon installing a covered process. The due date of the first audit could be based on three years from the initial process hazard analysis, the delivery of the covered chemical, or of the RMP Submit. However the initial date is determined, this due date for the first audit should be coordinated with the authority having jurisdiction (AHJ)—which is typically the CUPA in California.
As everyone knows, just because a policy exists, doesn’t mean it aligns with what is being practiced. Procedures and policies are great sources of information, but they do nothing to help businesses understand how well their program is being implemented. Policy documents are much like the body of the car. They may appear nice and shiny, but you won’t really know how the car is doing until you open up the hood and start poking around. It’s no secret—no one likes an audit. Most people think they’re as enjoyable as a trip to the dentist. But compliance audits can (and should be) extremely useful tools. A thorough compliance audit will not only identify deficiencies, but it will provide a path forward to better documentation, greater efficiency, and ultimately, a safer process.