2023 Jul-Aug RETA Breeze

• How much ammonia do you have? Go to the inventory calculation. • How do you drain this oil pot? Go to the Operating Procedure. • Who is in charge of the MOC’s? Go to the Management System. You get the idea. Going to the written plans and schedules gives you a consistent answer regardless of who is answer ing the question. Lastly, prepare yourself as the coordinator. Realize that this is a learning opportunity, both for you and for your Process Safety program. If you rely on an outside PSM/RMP consul tant or corporate resource, get them involved NOW before the audit has started! Remember that Process Safety is a Team Sport. Your audit team will include not only your site personnel but any corporate, 3rd-party consultant, and legal resources you have available. “Prepare the Facility” is about doing the last-minute things that show off your facility and your plan in the best light. Plan your site tour route with this in mind. If time permits, do some dusting, painting, labeling, and tagging as needed. A little bit of housekeeping goes a long way in establishing good will. LOOK at your system. A dented drain pan will draw questions about “struck-by hazards.” A fresh weld and unpainted pipe will draw questions about Management of Change and PSSR. If there is some ongoing maintenance or construction, perhaps this would be a good time to have them focus on another facility that isn’t being audited? DURING THE AUDIT It’s important to keep a few guidelines in place during your audit: • Remain Calm • Set the tone early • Keep a paper trail. Take pictures of what they take pictures of. Make copies of every document you provide them. • Ask for clarifications. If there is any confusion, ask for written questions • When in doubt, ask to get back to them. • Answer as briefly as possible • Wherever possible, answer with DOCUMENTS • Close the day and the audit with Thank You. “Remain Calm” is just about your attitude and professionalism during the event. Remember that they are auditing the program and the facility, not YOU personally. You want to keep this event focused on the program, so keep your politics and emotions to yourself. “Setting the Tone” is how you manage the “feel” of the audit. You can set the tone early with how you treat the auditor.

Regardless of how they treat you, treat the inspector as if they are a concerned friend trying to ask you some tough questions. That said: • Only give the minimum information needed to answer the specific question being asked. • Offer facts, not opinions – NEVER LIE TO AN AUDITOR! • Defend your program with every defensible argument, using all your available team resources. Another useful thought for “Setting the Tone” is to welcome the inspector. I know that sounds odd but think through this with me. Are you likely to get a better result if you treat the inspector as an enemy, or if you honestly say “We spend a lot time and resources on our Process Safety program, and are looking forward to finding ways to improve it.”This way of thinking brings the inspector on to your team – as people working together to address issues, rather than as a hostile force trying to tear you, and your program, down. “Keep a paper trail” is about making sure you KNOW what the inspector has. If they take pictures of something, you should take the same picture. If they ask for documents, you need to keep EXACT copies of the documents you provided them. “Asking for Clarification” is making sure you understand the questions being posed to you, including what the inspector

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