An effective Process Safety Management (PSM) System begins with understanding of each element associated in the OSHA standard. Then apply that knowledge in evaluating your system to identify any gaps in your program and/or implementation.
Process & Safety Solutions LLC (PSS) engineers and safety professionals can provide detailed auditing of your Process Safety Management (PSM) and Risk Management Plan (RMP) to identify any gaps that may exist. The audit or gap analysis is performed to determine conformance with OSHA’s Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) and/or EPA’s Risk Management Plan (40 CFR Part 68). PSS engineers and safety professionals have extensive industry and OSHA Compliance experience in process safety management. We have conducted numerous OSHA National Emphasis Program (NEP) audits of Refinery, Gas Processing, Petro-Chemical and Ammonia Refrigeration facilities. We have the knowledge and experience to ensure that all aspects of your programs are reviewed thoroughly.
PSS compliance audits address the 14 elements of the PSM standard and other related Safety Health Management Systems (SHMS) items. Through our experience we have found that each Ammonia Refrigeration facility will have 10‐15 gaps, Petro-Chemical, Refinery, and Gas Processing facilities will have 15-20 gaps that can result in costly OSHA/EPA violations. A violation of the OSHA 1910.119 standard is considered serious in nature and therefore can result in fines ranging from approximately $12,000 to $128,000 each due to a current proposal that is to take effect later in 2016. The most serious OSHA citations will have the higher proposed penalty amount of over $12,000 per citation.
It is important to note that OSHA does not treat the use of voluntary self‐audit reports as evidence as per its policy (Voluntary Self‐Audits). 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 preventing government citations and penalties, but also for abatement compliance, and removing the negative impact that a government news release can have on the reputation of your company throughout the community.