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.