#AhmedEltayef

Lessons Learned
from PSM Auditing
 OUTLINE
#AhmedEltayef

• What is an audit?
• Why are audits important?
• Regulatory requirements
• Audit procedure
• Common deficiencies found in PSM audits
• Considering a Maturity ModelTM
 WHAT IS AN AUDIT?

• An audit is a systematic, independent review to

#AhmedEltayef

verify conformance with established guidelines or

standards. It employs a well defined review
process to ensure consistency and to allow the
auditor to reach defensible conclusions. (Guidelines
for Auditing Process Safety Management Systems, 2nd
Edition, CCPS 2011)

• Systematic, independent and documented process

for obtaining audit evidence and evaluating it
objectively to determine the extent to which
the audit criteria are fulfilled. (ISO 19011:2011(en)
Guidelines for auditing management systems)
 WHAT IS AN AUDIT?
#AhmedEltayef

• An exercise in frustration
• An interruption of routine
• A threat to the facility
• A waste of time
• An unwanted intrusion into my life
• The ignorant leading the blind

Something THEY do to ME
 WHY IS
AUDITING IMPORTANT?
#AhmedEltayef

"Progress, far from consisting in change, depends on retentiveness.

When change is absolute there remains no being to improve and no
direction is set for possible improvement: and when experience is not
retained, as among savages, infancy is perpetual. Those who cannot
remember the past are condemned to repeat it."

George Santayana

"Those that fail to learn from history,

are doomed to repeat it."

Winston Churchill
 LESSONS FROM THE PAST
#AhmedEltayef

1989 Phillips
1984 Bhopal Pasadena

1979 Three Mile

Island

1976 Seveso

1974
Flixborough
 PROCESS SAFETY
REGULATIONS
#AhmedEltayef

• 29 CFR 1910.119, OSHA Process Safety Management of

Highly Hazardous Chemicals – Promulgated 1992
• 40 CFR Part 68, EPA Risk Management Program Rule –
Promulgated 1996
 ARE THE REGULATIONS
WORKING?
#AhmedEltayef

DuPont Insecticide Plant

2015

West Texas
2013

Deepwater
Horizon 2010

Buncefield
2005,
BP Texas
City 2005
 WHAT IS BEING DONE?

PSM Regulations have not changed since their

#AhmedEltayef

promulgation, but…
• Letters of Interpretation
• OSHA Petroleum Refinery Process Safety Management National
Emphasis Program (NEP) Directive – 2007
• OSHA PSM Covered Chemical Facilities National Emphasis
Program (NEP) Directive – 2011
• Executive Order 13650 (August 1, 2013)
– More chemicals, lower TQs, more covered facilities

• EPA revised the RMP Rule

 COMPLIANCE AUDIT
WHY?
#AhmedEltayef

• Excellent tool to assess an organization’s

Process Safety effectiveness – written
program and implementation
• Assess compliance; benchmark
performance with industry
• Identify and mitigate “early warning signs”
before a potential incident
• Integral to “PLAN – DO – CHECK – ACT”
cycle of continuous improvement
• Required under PSM/RMP
#AhmedEltayef

Regulatory Requirements
 ELEMENTS OF PSM
#AhmedEltayef

1. Employee Participation 8. Mechanical Integrity

2. Process Safety 9. Hot Work
Information 10. Management of Change
3. Process Hazard Analysis 11. Incident Investigation
4. Operating Procedures 12.Emergency Planning and
5. Training Response
6. Contractors 13. Compliance Audits
7. Pre-startup Safety 14. Trade Secrets
Review
 COVERED PROCESSES
AND CHEMICALS

• OSHA (29CFR1910.119)
#AhmedEltayef

– A process which involves a chemical at or above the specified

threshold quantities listed in Appendix A of OSHA 29CFR
1910.119
– A process which involves a Category 1 flammable gas or a
flammable liquid with a flashpoint below 100 oF on site in one
location, in a quantity of 10,000 pounds or more

• EPA (40CFR68)
– A threshold quantity of a regulated substance listed in §68.130 is
present at a stationary source if the total quantity of the regulated
substance contained in a process exceeds the threshold
 REGULATORY
REQUIREMENTS

Compliance Audits
#AhmedEltayef

• 1910.119(o)(1), 68.79(a): Employers shall certify that they have

evaluated compliance with the provisions of this section at least
every three years to verify that the procedures and practices
developed under the standard are adequate and are being
followed.
• 1910.119(o)(2), 68.79 (b): The compliance audit shall be conducted
by at least one person knowledgeable in the process.
• 1910.119(o)(3), 68.79 (c): A report of the findings of the audit shall
be developed.
 REGUATORY
REQUIREMENTS
#AhmedEltayef

Compliance Audits

• 1910.119(o)(4), 68.79 (d): The employer

shall promptly determine and document
an appropriate response to each of the
findings of the compliance audit, and
document that deficiencies have been
corrected.
• Employers shall retain the two (2) most
recent compliance audit reports.
 CORPORATE GOALS
#AhmedEltayef

• Gap analysis
• Communication of information and Feedback
• Performance Measurement
• Monitoring PSM program continuous
improvement
• Reducing the process safety risk
• Training of Auditors
• Sharing successful or best practices
 3RD PARTY
AUDIT PROCEDURE

• Lead Auditor puts a team put together

#AhmedEltayef

• An audit schedule is put together

• Request for information is sent to the facility
• An audit protocol is developed
• Site Tour
• Audit information is gathered through
– Interviews
– Site walk-through
– Records review
• Audit results are analyzed and findings are presented to the
facility
• A report is prepared and certified
#AhmedEltayef

Common Deficiencies
 COMMON DEFICIENCIES
#AhmedEltayef

Mechanical Integrity 202

Process Safety Information 189
Process Hazard Analysis 188 70%
Operating Procedures 184
Management of Change 92
Incident Investigation 71
Compliance Audits 47
Contractors 33
Training 29
 COMMON DEFICIENCIES
#AhmedEltayef

Emergency Planning and Response 17

Employee Participation 15
Pre-Startup Safety 13
Review
Hot Work Permits 8
Trade Secrets 0

Total PSM Citations 1088

 COMMON DEFICIENCIES
#AhmedEltayef

Mechanical Integrity 156

Process Safety Information 140 76%
Operating Procedures 114
Process Hazard Analysis 106
Management of Change 44
Compliance Audits 35
Training 21
Incident Investigation 19
Employee Participation 16
 COMMON DEFICIENCIES
#AhmedEltayef

Contractors 14
Emergency Planning and Response 7
Pre-Startup Safety 5
Review
Hot Work Permits 1
Trade Secrets 0

Total PSM Citations 678

 BASIS FOR
THESE STATEMENTS
#AhmedEltayef

• 350+ audits / assessments performed

• 2010 – 2016
• Large, major operating companies to smaller,
niche specialty chemical companies and
industries
 SITE WALK-THROUGH
OBSERVATIONS
#AhmedEltayef

Cracked Hoses

Leaking Liquids
 SITE WALK-THROUGH
OBSERVATIONS
#AhmedEltayef

Lack of ID
for Manual
Valves

Rusty Pipes Lack of Hazard Communication Signage

 COMMON DEFICIENCIES
DEFINITIONS OF
PSM BOUNDARIES
#AhmedEltayef

• Boundaries of PSM-covered process not well-defined or

documented; leading to inconsistent interpretation of PSM
boundaries across different departments and incomplete PHA
assessment
• Failure to include interconnecting utilities in the PSM-covered
process and PHA review process (e.g., steam, nitrogen, cooling
water, etc.)
Any possible solutions to this problem?
• SOLUTION: Redline/mark PSM-covered process boundaries on
Facility Plot Plan AND process P&ID(s) AND Communicate
 COMMON DEFICIENCIES
PROCESS SAFETY INFORMATION
#AhmedEltayef

• Hazardous effects of inadvertent mixing of

different chemicals that could foreseeably
occur not addressed
• Lack of complete Electrical Area
Classification documentation and field
survey
• Design basis information for emergency
relief/PSV and flare systems incomplete
(e.g., API RP520/521 RV sizing “contingency
analysis ” and flare analysis)
 COMMON DEFICIENCIES
• Design basisPROCESS SAFETY INFORMATION
information for safeguards,
#AhmedEltayef

which prevent or mitigate a potential

release, incomplete (e.g., fire water systems).
• Materials of construction information not on
file for all equipment in the “covered
process”.
• Lack of reference Plant design codes and
standards identified (“RAGAGEP”).
 COMMON DEFICIENCIES
PROCESS SAFETY INFORMATION
Standard Title
#AhmedEltayef

API 520 Sizing, Selection & Installation of Pressure-Relieving Devices in

Refineries
API 521 Pressure-Relieving and Depressuring Systems
API 752 Management of Hazards Associated with Location of Process
Plant Permanent Buildings
API 753 Management of Hazards Associated with Location of Process
Plant Portable Buildings
API 510 Pressure Vessel Inspection Code – In-service Inspection,
Rating, Repair and Alteration
API 570 Piping Inspection Code – In-service Inspection, Rating, Repair
and Alteration of Piping
API 574 Inspection Practices for Piping System Components
ANSI/ISA Functional Safety – Safety Instrumented Systems for the
S84.01 Process Industry Sector
 COMMON DEFICIENCIES
PROCESS HAZARD ANALYSIS

• PHA fails to comprehensively identify all

#AhmedEltayef

hazards of the process because:

– Selection of the wrong methodology based on complexity
of the process
– Incomplete set of Guidewords + Parameters
(“Deviations”) utilized
– Failure to review Startup / Shutdown issues, Abnormal
Operations
Can you recall an incident that happened
during start-up?
 COMMON DEFICIENCIES
PROCESS HAZARD ANALYSIS

• PHA performed in the absence of at least one

#AhmedEltayef

employee who has experience and knowledge

specific to the process being evaluated.
• Failure to assess consequences to “ultimate” loss
event assuming safeguards are non-existent or
ineffective as designed.
• Safeguards not independent of the initiating event
/ cause. Failure to perform Layer of Protection
Analysis (LOPA) to assess effectiveness of
safeguards.
 COMMON DEFICIENCIES
PROCESS HAZARD ANALYSIS

• Previous incidents, including “near

#AhmedEltayef

misses”, not considered by the

PHA team.
• Overdue PHA recommendations
with no managed schedule for
resolution and completion.
• Incomplete compilation of Process
Safety Information prior to
performing the PHA.
 COMMON DEFICIENCIES
PROCESS HAZARD ANALYSIS
#AhmedEltayef

• Process hazard analyses were not updated

and revalidated at least every five (5) years.
• Failure to address FACILITY SITING issues.
• Failure to address HUMAN FACTORS issues.

USE I N DUSTRY-STAN DARD CHECK LI STS!!!

 COMMON DEFICIENCIES
OPERATING PROCEDURES

• SOPs not written for ALL phases of operation (esp.,

#AhmedEltayef

non-routine operations, e.g., purging, cleaning,

sampling, temporary operation, emergency operation,
etc.)
• Safe operating limits and consequences of deviation
from these limits not well-defined. Steps to
correct/avoid deviations not documented
• No written procedures for Shift Change / Handover
operations
• Lack of annual certification
 COMMON DEFICIENCIES
SAFE WORKING PRACTICES
#AhmedEltayef

• No documented
Equipment-specific
procedures for LOTO,
Confined Space
• Lack of periodic training
for LOTO, Confined
Space
 COMMON DEFICIENCIES
MANAGEMENT OF CHANGE

• MOC process not applied for:

#AhmedEltayef

• Installation of temporary equipment

• Decommissioning or taking equipment out-of-
service
• Changes to alarm setpoints
• Procedural-only changes (e.g., conversion from
paper-based to electronic systems)
• Changes in shift work; workforce reductions
Why do you think it is important to address
organizational changes?
 COMMON DEFICIENCIES
MANAGEMENT OF CHANGE
#AhmedEltayef

• PSI, SOPs, M.I. not updated when affected

by the MOC.
• MOC forms completed and signed off
before PSSR completed.
 COMMON DEFICIENCIES
MECHANICAL INTEGRITY

• “FIX IT WHEN IT BREAKS” mentality

#AhmedEltayef

• Failure to identify “critical equipment” relative to the

PSM-covered process
• Lack of written deficiency management program for
non-conformances identified during inspection and
testing activities
• Overdue inspections
• Failure to identify and implement RAGAGEPs for
inspections and tests
 COMMON DEFICIENCIES
MECHANICAL INTEGRITY

• Failure to review PHA and include all “safeguards”

#AhmedEltayef

in Mechanical Integrity program.

• Focus on stationary equipment; less emphasis on
Rotating Equipment and Instrumentation &
Controls.
• Lack of “fitness for service” documentation for
process equipment.
• MOC process not used for changes to inspection
frequency.
 COMMON DEFICIENCIES
INCIDENT INVESTIGATION

• “Near misses” not recorded;

#AhmedEltayef

possibly due to:

– Lack of good, uniform
understanding of what the Level 1
definition of a “near miss” Incidents of
greater
consequence
– Lack of positive culture that
Level 2
promotes reporting of “near Incidents of lesser
consequence
misses” Level 3

• Focus on reporting and Challenges to safety system

Level 4
investigation of personnel safety Operating Discipline & Management System
Performance Indicators.
incidents (a “lagging” indicator) (Not reported yet in RCI)

versus “near misses” (a leading

indicator)
 COMMON DEFICIENCIES
TRAINING

• Missing records of initial training for qualified

#AhmedEltayef

operators.
• Refresher training not conducted
• at least every three (3) years.
• Lack of verification of personnel comprehension of
training program.
• No written proof that operators were consulted on
frequency or content of refresher training.
• Refresher training too focused on “normal” operations.
 COMMON DEFICIENCIES
CONTRACTORS

• Lack of due diligence qualification, certification

#AhmedEltayef

records for contractor employees who perform

“specialized skill or craft work”, e.g.,
– Crane and rigging work
– Forklift driving, mobile lifts/JLGs
– Certified welding
– Instrument calibration
– Other

• Lack of periodic surveillance of contractors post-

selection; contractors only disciplined when
something goes wrong
 COMMON DEFICIENCIES
EMPLOYEE INVOLVEMENT
#AhmedEltayef

• Lack of well-articulated management

expectations and defined goals; leading to
weak employee morale and decreased
employee participation.
• Employees do not know how to access PHAs
and other PSM information.
 Considering the
#AhmedEltayef

Maturity Model™
PSRG’s Maturity ModelTM is an extension of the
business practice of examining the maturity of a
business process by comparison to a set of
indicators and assigning a score. Its best and
highest use is to align Process Safety
Management as a business practice in the minds
of corporate executives.
 MATURITY MODEL

• Based on Levels 1-4 where

#AhmedEltayef

1 is Reactive and 4 is Level Definition

Optimized (Best-in-Class) 1 Reactive/Initial

• Ability to gauge overall as 2 Dependent/Defined

well as individual PSM 3 Managed/

Independent
element performance Managed
4 Optimized/
Interdependent
• Model defines Best-in-
Class Safety Management
System
 MATURITY MODEL
#AhmedEltayef

Level 3: Managed/
Level 1: Level 2: Level 4: Optimized/
Reactive/Initial Dependent/Defined Independent
Interdependent
Managed
• Immature safety • Structured and • Individuals use wide • Everyone takes
system, procedures documented policies range of tools and proactive approach,
reviewed when with focus on behaviors to care for peer to peer focus,
needed. following procedures themselves with assessment through
• Employer meets less • Good understanding managers taking continuous
than 80% of the of the requirements action when needed. improvement.
criteria developed in outlined in 29 CFR • The employer meets • The employer has
Level 4. 1910.119. at least 90% of the consistently achieved
• The employer meets criteria developed in 98% of the criteria
at least 80% of the Level 4. developed for the
criteria developed in past three PSM
Level 4 audits as certified by
external auditors.
 EXAMPLE CHECKLIST
MATURITY MODEL

Element Level 1 Level 2 Level 3 Level 4

#AhmedEltayef

Process • Hazards inadequately • Procedure developed • Procedure developed • Procedure developed with
Hazard addressed with methodologies with methodologies methodologies including
Analysis • Lack of full team • Subsequent PHAs including LOPA LOPA
member ID and timely updated or • Subsequent PHAs timely • Subsequent PHAs timely
Expertise revalidated updated or revalidated updated or revalidated
• No system to • Employees trained in before 5-year anniversary before 5-year anniversary
promptly address leadership or PHA • Employees trained in • Employees trained in
recommendations participation leadership or PHA leadership or PHA
• Actions not • Pre-formatted participation participation
communicated to industry standard • Pre-formatted industry • Pre-formatted industry
working groups templates used standard templates used standard templates used
• Not timely • Team members and • Team members and • Team members and areas
updated/revalidated areas of expertise areas of expertise of expertise identified
within 5 years identified identified • Comprehensive reports
• Not retrievable • Comprehensive • Comprehensive reports • System to promptly
reports • System to promptly communicate
• System to promptly communicate recommendations
communicate recommendations • Tracking System for
recommendations • Tracking System for actions includes metrics
• PHA revalidated actions includes metrics • Findings/Actions
every 5 years • System to promptly communicated to affected
• Records Retrievable communicate workforce
actions/findings • 5 year PHA schedule
• 5 year PHA schedule developed, reviewed
developed annually for planning and
team assignment
 COMPARISON TO
STYLES OF BENCHMARKING
#AhmedEltayef

5 Maturity Score
Level
Target (Best-in-Class)
4 Between 1 (Below Compliance)
C Level 1 & 2
3
Level

2 A Level 2 2 (Compliance)
B Between 3 (Compliance plus)
1 D Level 2 & 3

0 Level 4 4 (Best-in-Class)
Facility
Levels 1-4 where 1 is below par and 4 is
Best-in-Class
 IN SUM
#AhmedEltayef

• Why is Auditing Important

• Regulatory Requirements
• Common PSM Audit Deficiencies
• PSRG’s Process Safety Management Maturity
Model™
 SOME REFERENCES

• Guidelines for Auditing Process Safety

#AhmedEltayef

Management Systems, 2nd Edition, CCPS

(Center for Chemical Process Safety), 2011
• (ISO 19011:2011(en) Guidelines for auditing
management systems)
• U.S. Chemical Safety and Hazard Identification
Board, Investigation report, report No. 2005-
04-I-TX, Refinery Explosion and Fire, 2007
• The Environmental Health and Safety
Auditor’s Handbook (Greeno et al., 1987)
 WHAT IS AN AUDIT?
#AhmedEltayef

• An exercise in frustration
• An interruption of routine
• A threat to the facility
• A waste of time
• An unwanted intrusion into my life
• The ignorant leading the blind

Something THEY do to ME
 3RD PARTY PERSPECTIVE
FOR A SUCCESSFUL AUDIT
#AhmedEltayef

SOMETHING THEY DO TO ME

MUST BECOME

SOMETHING WE DO TOGETHER
#AhmedEltayef

THANK YOU