Document # HSE / PSM / Level-I / 10 Date Prepared: December 2008

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Revision: 02 Revision Date: October 2016

PSM 10 - AUDITS &

OBSERVATIONS

AUTHORIZATION:

Prepared By: ____________________________ Reviewed By: ________________________

Ammar Hussain Rizwan Ahmed Taqi
HSE Engineer Chairman Sub-HSE (PSRM)

Reviewed By: ____________________________ Approved By: ________________________

Syed Muhammad Farooq Ahmed Jahangir Waheed
Safety Advisor VP Manufacturing

Reviewed By: ________________________ Approved By: ________________________

Farrukh Iqbal Qureshi Imran Anwer
HSE Manager President & CEO

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-I / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

Scope:
This Document describes the requirement for complying with the Process Safety
Management element on Audits & Observations

Change Record:
All changes have been highlighted in Grey

Sr. # Date Rev. # Page # Section Change Description

1 Oct‘14 01 All All Document Format has been changed
2 Oct‘16 02 All All Document Format has been changed
PSRM 14 – Auditing and PSM 12 – Effective Audits have
3 Oct‘16 02 All All
been merged into PSM 10 – Audits & Observations

SECTION-1 TABLE OF CONTENTS

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-I / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

SECTION-1 TABLE OF CONTENTS...............................................................................................................3

SECTION-2 PRINCIPLE..................................................................................................................................4
SECTION-3 ESSENTIAL FEATURES...............................................................................................................5
3.1 TYPES OF AUDITS................................................................................................................................................................................... 5
3.2 AUDIT PLANNING AND FREQUENCIES.................................................................................................................................................5
3.3 INTERNAL AUDIT PROGRAM................................................................................................................................................................. 6
3.4 EXTERNAL AUDIT PROGRAM.................................................................................................................................................................7

SECTION-2 PRINCIPLE

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-I / 10 Date Prepared: December 2008
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EPCL believes that audits are important tools in the establishment, measurement,
maintenance and continuous improvement of process safety performance. Audits compare
performance vs. established standards and evaluate effectiveness of systems in
accomplishing their intended purpose. Proper auditing provides a process that nourishes
and reinforces correct systems, behavior and work practices while identifying opportunities
for improvement.

Studies have shown that more than 90 percent of all injuries and incidents are the result of
unsafe acts. Programs that concentrate on eliminating these acts greatly improve safety
performance. Field audits that focus on people working can prevent incidents by alerting
workers and managers to an unsafe work habit or act before it causes an injury. Safety audits
are a line responsibility; they are not the exclusive job of the Safety Personnel. The line
manager must enforce standards for his area. Frequent formal and informal audits are the
best way to accomplish this.

SECTION-3 ESSENTIAL FEATURES

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
Document # HSE / PSM / Level-I / 10 Date Prepared: December 2008
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Revision: 02 Revision Date: October 2016

 Site management shall develop safety audits program to establish a set of audits to
ensure the effectiveness of safety design, operability and reliability. Some of the audits
should also fulfill Government and OSHA regulatory requirements. Others may be
required due to previous findings and accidents investigations.
 Company & Division level HSE committees form sub-committees at corporate and site
level to deal with the process of safety audits. As an alternate, they should directly
oversee the process of safety audits.
 MHSE sets a management expectation for personal behavioral audits in all operating
areas on at least a weekly basis.
 The audits should focus on one-on-one contact between middle managers and
workers. More direct contact between supervisors and workers, talking about safe work
behavior is greatly needed.
 The audits should involve EPCL & Contract Employees in recognizing and correcting
unsafe behavior and unsafe conditions.
 The management should ensure compliance of safe work practices & relevant
standards during the audits.
 The line managers are responsible for timely completion of areas of improvement
highlighted in the audits.
 The audit results should be stewarded with the Sub HSE on regular basis.

3.1 Types of Audits

At a minimum, following audits shall be planned and conducted through well established
procedures at the site:

 Process Safety Management (PSM) Internal Audits

 PSM External / Third Party Audits
 Safety Critical System Audit

3.2 Audit Planning and Frequencies

The Site management shall comply with the following audit planning and frequency
requirements:
 Establish a 3 year plan of audit programs
 The audits plan shall be stewarded yearly by MHSE and essential changes made.
 Internal audits of the PSM programs and their status in each area should be completed at
least once every three years.
 The MHSE chairman is responsible for conducting appropriate internal / external audits
of PSM systems and their implementation.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
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3.3 Internal Audit Program

3.3.1 PSM Internal Audits
The Site shall have an internal PSM audit program that conducts internal audits of all the
elements of this standard. Program shall assess system implementation, performance and
program effectiveness in each process unit. The Site shall establish and implement written
procedures to conduct the audits.

The internal audit program should address the following mandatory and advisory elements:

 The line organization can conduct internal audits.

 Audits shall be conducted using the Site protocols and checklists (or the equivalent).
Checklists shall include the requirements of PSM essential features and procedures.
 Audit teams shall include at least one person who has had training in the essential
features of PSM and one person who is knowledgeable and experienced in the element
being audited.
 The leader of site’s subcommittee on PSM audits shall have completed:
o A two-day course on the principles and essential features of PSM.
o The PSM audit-leader should have participated in a previous audit.
 Audit team leader should have:
o Completed a two-day course on the principles and essential features of PSM or
the equivalent.
o Participated in at least two PSM audits as a member of the audit team.
o An understanding of the PSM element(s) being audited and successful systems
utilized to comply with those elements.
o Minimums of three years of site operating, maintenance, technical or safety
experience.
 Results shall be documented and reported to the Sub HSE.
 Findings of noncompliance shall be promptly addressed and corrected. Findings shall
include responsibility for follow-up and timing.
 Actions taken to close findings shall be documented with the audit report.
 Site shall retain the most recent (current report) PSM audit report.
 Stewardship of audit recommendation should be conducted on regular basis.

3.3.2 Area Audits

Self-analysis facilitates implementation of recommendations from an audit, reinforces
understanding of priorities, and prepares the area for internal / external audits.

 Site management shall ensure that audit of PSMs relevant to his area is conducted thru
line organization.
 The audit frequency should be at least once a year.
 Team must include personnel who are knowledgeable in the process and may include
members from site’s Sub HSE (PSM).
 The audit recommendations should be addressed within the assigned target date to
ensure safe operations and better score in site’s internal / external PSM audit.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed
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3.3.3 Hazardous Substance Survey

EPCL is committed to the safe operation of its facilities. This commitment requires that all
potential safety hazards are systematically identified and the risk from these hazards is
managed in such a way that those employees, the public, and the environment are
protected.

The primary objective of the survey is a realistic appraisal of activities and conditions related
to handling and storage etc. of hazardous substances and pointing out areas for
improvement. Auditors should be carefully chosen with expertise to know what to look for
and to recognize deficiencies when they exist. The audit is conducted using a checklist.

Site management shall ensure following is in place:

 Hazards of all chemicals / substances should be clearly defined.

 Requirements for safe handling, transportation, storage and usage should be clear
defined and understood.
 Training and audit requirements and frequencies to be documented.
 Emergency Response protocol should be established.
 Safe disposal of substances/chemicals to be defined.

3.3.4 Safety Critical System Audit

Site management shall ensure that safety critical devices, equipment and systems are well
managed. The focus shall be given to:

 Personnel knowledge about the system

 Defeat of all the safety critical devices and systems is controlled.
 Deficiencies in the system found, reported and stewarded to have complete compliance
of the system.

3.4 External Audit Program

 The external audits will be conducted by a professional / team of professionals from outside EPCL
who have in-depth knowledge of PSM systems. Such audits provide an "outside view" on how the
Site is doing and provide opportunities for two-way "sharing" of good ideas and practices
 The site should provide qualified personnel (as team members) to assist the external audit team
for conducting the audit.
 The site must complete external audit at least every three years. Manufacturing HSE Chairman is
responsible to comply with this requirement.
 In case, the audit cannot be arranged at the required frequency, due to some unavoidable
circumstances, the Manufacturing HSE Chairman may give a waiver specifying reasons why the
audit could not be conducted as per schedule. New program for the audit should also be
specified in the audit report. However, such audit waivers shall be shared in Corporate HSE
committee.

Prepared By; Ammar Hussain Reviewed By: SMF/ FIQ/ RT Approved By: Jahangir Waheed