April 28-May 1, 2013
San Antonio, TX
Call for Papers
Title: Identifying Root Causes in Auditing
David M. Heller, CSP, CPSA, Manager, DC Business Unit, Richard A. Santo, Jr., Principal Engineer, David A. Kahn, Sr. Associate Engineer
AcuTech Consulting Group
1600 Tysons Blvd., Suite 800
McLean, VA 22102
Process safety management auditing has historically consisted of examining a facility on an element-by-element basis, developing findings and recommendations. It is also possible to look for, and identify deeper, root causes that may be the source of multiple audit findings. Identifying and correcting these root causes may result in longer and deep-seated impacts to a PSM program.
The auditing root cause approach has benefits for single sites, but has the potential for even greater benefits if significant common root cause findings are identified between multiple sites that can be addressed at a group or corporate level.
Often, the root cause findings are found in the realm of process safety culture. Examples include:
- A culture of “compliance only”. Multiple sites are focused on basic compliance with OSHA PSM (for example, or Seveso or KOSHA for international sites), not “compliance plus”. The sites would benefit from setting their goals to exceed, rather than just meet, the regulatory requirements.
- An “inwardly focused” or “parochial” culture exists. When sites develop their PSM programs internally, without benefitting from the expertise at other sites or around industry – PSM audits are conducted largely by site personnel; PHAs are led by site personnel; the mechanical integrity program is developed by site personnel, etc. This is often evidenced by a relative lack of action items generated from past audits and PHAs.
- A culture of “normalization of deviation” exists. Issues that are readily apparent to outside observers are not noticed by plant personnel. Examples include: acceptance of large numbers of open/backlogged items and plant personnel not reacting to unsafe acts or conditions during plant walkthroughs with external auditors.
This paper will outline the process of identifying auditing root causes, with examples, and provide examples of how to develop overarching recommendations to address these issues.
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