2023 Jul-Aug RETA Breeze

PREPARING FOR AN RMP / PSM INSPECTION OR AUDIT

“By failing to prepare, you are preparing to fail”— Benjamin Franklin Having your Process Safety program audited or inspected can be very stressful. Here are some tips on things you can do to improve your audit results. They break down into three categories: Before, During, and After the audit. BEFORE THE AUDIT You may not have advanced warning of an Audit, but if you have time to prepare you should focus on these three topics: • Know your Program

If your program is well organized and reflects your practices, your next step is to look at all your open recommendations and action items. PHA’s, MOC’s, PSSR’s, Incident Investigations, MI reports, previous Audits, etc. tend to have action items or recommendations. If those aren’t addressed, they can each be turned into audit findings. Realize that you are doing the auditors’ job for them, as each of these recommendations is a finding of non-com pliance or an unsafe condition. “Preparing your staff” is simply allowing the people in your facility to make their own preparations for the audit. Remind them that their answers should be made by referring to the written program, and not recited from memory.

“Knowing your Program” is a large topic. Since a PSM/RMP program is a written program, you need to let it speak for you, and this requires you to know where all your documents are and how can you easily access them. Now that you know your documents are available, are they accurate and consistent? Start with your Management System (where you say who are the Responsible Persons for each PSM/ RMP element) and then work through your individual element written plans. As you get into those written plans, do they accurately reflect what your practices are? For example, if you say you conduct a walkthrough every 8-hrs in your documen tation, can you provide documents of those walkthrough’s occurring on that written schedule?

• Prepare your staff • Prepare the facility

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