How to Minimize Audit Findings By Achieving a Sustainable and Sound Process Safety Culture

Many major accidents have taken place in the chemical and petrochemical industry over the past 40 years (e.g. Bhopal (India, 1984),Texas City (USA, 2005); which have been key driving forces for issuing new regulations (governments), publishing standards (industry groups), developing policies (companies), and ultimately for improving Loss Prevention strategies and Process Safety Management (PSM). On this context, a key standard is the OSHA PSM (29 CFR 1910.119), a process based program aiming at preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals.

The present paper focuses on the results from several PSM audits performed between 2010 and 2016, at several different Chemical Process Industry (CPI) facilities. On the one hand, we have evaluated how well these facilities complied with the requirements of the OSHA PSM Standard. On the other hand, the data from the audit findings has been compiled and statistically processed, in order to compare the main common findings with the results of those analyzed by OSHA’s Refinery and Chemical National Emphasis Programs (NEP) in 2012.

The scope of the audits included all 14 PSM elements. Moreover, it also included an assessment of the applicability of the standard based on the chemicals handled on each specific site. The audit findings were classified according to three different categories: Regulatory (non-compliant), Recognized And Generally Accepted Good Engineering Practices (RAGAGEP), and Local Attention.

The results from the statistical analysis highlights trends and provides detailed conclusions on how to potentially link actual industry weaknesses (audit findings), via maximizing the importance of implementing a sound Process Safety Culture (supported and followed from top Management, through operations and maintenance, to all facility workers).

Key audit findings from the CPI are a valued source of information for understanding current weaknesses. The lessons learned from this study help us to identify process safety leadership and culture benefits towards minimizing or avoiding audit findings, and therefore, to contributing to an optimized and sustainable Process Safety management system.