Compliance Audit/Gap Analysis

Extensive industry and regulatory knowledge are essential for evaluating PSM and RMP programs. Our lead auditor brings this knowledge with both industry and regulatory experience as an OSHA PSM compliance specialist and has conducted over 200 Chemical and Refinery National Emphasis Compliance Audits and inspections. Our unique background allows us to conduct compliance evaluation and provide solutions that result in the continuous improvement in process safety, with an emphasis on program implementation.  Understanding and addressing gaps in your process safety programs lead to safer facilities, high moral, and the retention of highly skilled and trained personnel.

PSS compliance audits address the 14 elements of the PSM standard and other related SHMS items. Our experience has found that we can expect 10-20 gaps, depending on the facility, that could result in OSHA or 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.

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 (PSI) required for the audit. Information needed may include process descriptions, flow diagrams, process hazard 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, 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 ranges from 3-5 days depending on the number of process or unit operations being audited.  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.

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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


Confined Space Entry

Respiratory Protection


Emergency Action or Response Plan


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