Surviving an OSHA PSM National Emphasis Program Audit

The Occupational Safety and Health Administration (OSHA) instituted a “National Emphasis Program” to conduct both targeted and random inspections of facilities subject to the Process Safety Management (PSM) regulations.   OSHA responded to several high profile incidents by initiating a program to help assure that facilities handling highly hazardous chemicals are meeting the PSM regulations in an effort to reduce incidents. OSHA is currently inspecting or auditing PSM facilities and will indeed issue citations if the facility does not meet all of OSHA’s requirements. This paper presents the results of the most commonly found deficiencies at the facilities and also provides information that can be used to make sure that a facility’s PSM program will indeed pass an OSHA inspection under the National Emphasis program.

The Process Safety Management standard is “performance” based which means that companies must demonstrate compliance through programs and policies in place.   Auditing a “performance based” system can be abstract as the auditing protocols may not be definitive. Both the operators of facilities and the regulators rely on recognized and generally accepted industry practices and past letters of interpretation from OSHA to help determine if a facility’s PSM program is meeting the requirements of the regulations.   

However, there are still definitive requirements in the PSM standard that plant operators must comply with.   Given these facts, it is critical that a facility undergoing a PSM review make sure that programs and policies designed to meet PSM requirements are fully documented, communicated and implemented. 

OSHA initiated the “PSM Covered Chemical Facilities National Emphasis Program” in 2011.  Over the past three years many plants have undergone PSM compliance reviews.   Industry has learned from these reviews where common vulnerabilities exist in their programs, more about what OSHA is looking for in terms of compliance and also how to improve PSM efforts.

This paper presents information learned by both industry and OSHA about how PSM compliance efforts can be improved.    The technique presented in the paper to improve PSM programs enables the facility operator to make sure that their PSM compliance efforts are in line with industry norms and OSHA’s expectations for compliance.   The result of implementing the findings and recommendations found in this report will help industry to improve process safety performance and regulatory compliance resulting in fewer PSM related incidents.