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The Process Safety Professional. Part 6: Process Safety Assessments
There is always news about safety, and some of that news will be bad.
This post discusses the distinction between Process Safety Assessments and Process Safety Audits. It provides guidance to do with the development of Assessment protocols.
Audits are a fundamental feature of all successful management programs. Line managers need to know how they are performing, and senior management needs a means of checking that all the rules and standards are being followed. Audits are needed in order to identify that bad news. For these reasons, most process safety programs require that the system be audited on a regular basis, say once every three years.
OSHA Audit Requirements
The following is the OSHA requirement to do with auditing process safety programs. It is based on para. 1910.119(o) of their standard.
1910.119(o) Compliance Audits
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. 1910.119(o)(2)
The compliance audit shall be conducted by at least one person knowledgeable in the process.
A report of the findings of the audit shall be developed.
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.
Employers shall retain the two (2) most recent compliance audit reports.
EPA RMP Audit Requirements
The following summarizes the EPA Risk Management Program (RMP) requirements.
Pursuant to the risk management program regulations, facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79).
Nature of Audits
A formal audit is primarily a compliance exercise. The auditor is provided with an objective standard such as a regulation, an industrial code or an internal company document. He or she then determines if the facility being audited complies with the requirements of that standard. The audit is fundamentally a ‘Yes/No’ exercise. Either the facility is in compliance, or it is not.
For example, the following statement is taken from the OSHA standard to do with operating procedures.
The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting an initial startup;
Given this standard, an auditor could point to a piece of equipment such as a compressor and say to the technician who operates it, “Show me the procedure for starting this compressor.” If the technician produces that procedure in a timely manner, then demonstrates how he or she follows the steps of the procedure, and can finally show that the procedure is up to date, then the audit requirement is satisfied.
The essential point is that the auditor is not asked to provide an opinion on the quality of the procedure. He or she limits their evaluation to whether it meets the specific requirements of the relevant standard. Moreover, if the auditor does find a deficiency, he or she is not required to come up with a solution.
The auditor needs to be skilled at conducting audits, and should have a working knowledge as to how energy or process facilities work. But he does not need to be an expert in the matter being audited. In this example, the auditor should understand the general use and operation of compressors, but he or she does not need to be an expert in compressor design and operation.
In practice, many auditors will supplement their findings with insights based on their own experience and knowledge. But, when they do so, they are not actually auditing — they are conducting an assessment or review. These insights could be very valuable, but they are not, strictly speaking, part of the formal audit.
A review or assessment is less formal than an audit. The reviewer evaluates the facility’s performance, and, based on his or her experience, provides opinions as to the quality of and effectiveness of the facility’s program and its implementation. Returning to the compressor example, if the reviewer does have expertise in with this type of equipment, then he or she can offer advice as to the quality and usefulness of the operating procedures.
The facility's management may authorize an assessment because they are looking for deeper insights than those provided by a formal audit. In the case of the example to do with starting the compressor, the auditor’s report may say that the operating procedure meets the standards that are being followed. However, management may be aware that there have been a number of operational upsets to do with compressor startups, and that some of those upsets can attributed to inadequate procedures. Therefore, they look to the assessor to identify where the problems lie, and how improvements can be made.
Management may also be looking for help in areas that are not directly to do with safety. For example, the facility may be spending too much money maintaining compressors. Management would like advice as to how these costs can be reduced. One way of meeting this need may be to improve the manner in which the compressors are operated.
Process safety regulations are mostly performance-based. They do not provide detailed, specific rules as to what a company must do. They basically say, “Do what it takes to operate safely. It is your responsibility to determine how this can be achieved.” This strategy calls for assessments to supplement formal audits.
A knowledgeable reviewer can provide examples of best practices. Using the compressor example, once more, he or she may be able to provide examples of operating procedures from other companies, including compressor manufacturers.
Continuing with the example of the compressor startup procedures, a reviewer or assessor might ask questions such as,
Is this procedure too long?
Is it too short?
Can it be used outside at night in the pouring rain?
Is it written at the correct comprehension level?
Have the instructions from the compressor manufacturer been incorporated into the startup procedures?
And — the most important question of all — does anyone actually use this procedure, or does it sit on a shelf or on a hard drive quietly gathering dust?
There are no right or wrong answers to these questions (apart from the last one). One person may consider the procedure to be the right length, another may disagree. Such a disagreement, as long as the parties remain polite, is healthy. It forces everyone to examine the usefulness and relevance of the procedures and to determine if they are actually helping to make the facility safe and profitable. Unlike the formal audit, an assessment rarely provides a company with a simple “Yes/No” response.
The assessor may also provide a ranking or score to his or her findings. The scoring system may look something as follows:
‘0’ — Missing / Not Acceptable
‘1’ — Unsatisfactory / Poor
‘2’ — Adequate
‘3’ — Good
‘4’ — Excellent
‘N/A’ — Not applicable
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