Compliance Audit/Gap Analysis

Process & Safety Solutions LLC (PSS) engineers and safety professionals can provide auditing of all aspects of your Process Safety Management (PSM) and Risk Management Plan (RMP) program and identify any gaps that may exist. The audit or gap analysis is performed to determine conformance to OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) and EPA’s Risk Management Plan (40 CFR Part 68). PSS engineers and safety professionals have significant industry experience as well as experience as OSHA compliance officers in the arena of process safety management. We have conducted over 100 OSHA National Emphasis Program (NEP) audits of Refinery, Gas Processing, Petro-Chemical and Ammonia Refrigeration facilities and have the knowledge and experience to ensure that all aspects of your programs are reviewed through both industry experienced eyes and those of OSHA/EPA as well.

PSS compliance audits address the 14 elements of the PSM standard and other related SHMS items. Our experience has found that we can expect each Ammonia Refrigeration facility will have 10-15 gaps and Petro-Chemical, Refinery, and Gas Processing facilities will have 15-20 gaps that could result in OSHA/EPA violations. A violation of the OSHA 1910.119 standard is considered serious in nature and therefore can result in a fine ranging from $12,934 to $129,336 each.  Most serious OSHA citations have a proposed penalty amount of $12,934 per citation.

OSHA does not treat the use of voluntary self-audit reports as evidence of willfulness per its policy (Voluntary Self-Audits).  Consistent with the prevailing law on willfulness, if an employer is responding in good faith to a violative condition discovered through a voluntary self-audit and OSHA detects the condition during an inspection, OSHA will not use the voluntary self-audit report as evidence that the violation is willful.  OSHA’s policy is intended to apply when, through a voluntary self-audit, the employer learns that a violative condition exists and promptly takes diligent steps to correct the violative condition and bring itself into compliance, while providing effective interim employee protection, as necessary.

The PSS audit/gap analysis has an excellent return on your investment not only in avoidance of government citations and penalties but the time involved for abatement, plus the negative impact that a government news release could have on the reputation of your company in the community.

The PSS gap analysis and/or compliance audit follows a three-step process:

Step 1: Information Collection

Our safety engineers and professionals work closely with site personnel to collect pertinent Process Safety Information required for the audit. Time spent on this activity helps to minimize the time required for the on-site visit. Information needed may include process descriptions, flow diagrams, process hazards analysis, site equipment layout drawings, and written policies and procedures.

Step 2: Site Visit 

The auditor(s) will visit the site for a physical audit. During this visit, the auditor(s) will complete record reviews, make visual observations, and conduct interviews with site operations, production, and maintenance personnel, as well as contract personnel, in order to evaluate compliance. For OSHA and EPA compliance, a detailed checklist will be completed following all aspects of the standards.

Step 3: Reports and Documentation

The average onsite audit timeframe ranges from 3-5 days. A longer timeframe will be necessary based on the number of process or unit operations being audited. For an Ammonia Refrigeration or simple Gas Processing facility, auditor(s) will be onsite for approximately 3 days. At the end of the site visit a review of the preliminary findings or gaps will be presented to the client’s site staff personnel. The auditor(s) will submit a written report to the client that will contain findings, observations, and suggestions concerning any deficiencies found in the PSM and RMP covered portions of the site. The PSS engineers and professionals will offer insight and recommendations as appropriate to advance the site’s programs based on the regulatory requirements and industry best practice.

Schedule Today:

To schedule your compliance audit or gap analysis, please call, web chat, or email us. We will send you a detailed list of documents we need to review prior to the site visit and a list of documents we need for the onsite portion of the evaluation. The documents will be based on your facilities operations and the documents that you have on site.

For further information about gap analysis please email us at info@pssolutions-llc.com

The typical compliance audit consists of evaluating programs and documents associated with but not limited to:

  • Process Safety Information (PSI)
  • Process Hazard Analysis (PHA)
  • Mechanical Integrity (MI)
  • Standard Operating Procedures (SOP)
  • Management of Change (MOC)
  • Pre-Startup Safety Reviews (PSSR)
  • Contractor Evaluations & Qualification Processes
  • Operator Training
  • Incident Investigations
  • Lockout/Tagout
  • Confined Space Entry
  • Respiratory Protection
  • HAZWOPER
  • Emergency Action or Response Plan

THE AUDIT IS CONDUCTED IN SEVERAL STEPS THAT INCLUDE:

  • Employee, Operations, and Management Interviews
  • Review of PSI, Testing, and Inspection Records
  • Review Applicable Recognized and Generally Accepted Good Engineering Practice (RAGAGEP)
  • Review personnel Training Records
  • Final Report
  • Gap Analysis & Review
  • Gap Resolution Schedule & Responsibility