A major pulp and paper manufacturing company in Mississippi determined that its process safety management (PSM) program had to do more than merely follow OSHA regulations; they wanted it to also be effective in preventing accidents. Traditional audit programs examine documentation and procedures; however, they do little to evaluate the program quality or effectiveness. Accidents can still happen even if PSM procedures meet OSHA and EPA requirements.
ioKinetic developed a quality process safety management audit protocol to dig below the surface of their process safety programs and evaluated their quality. A particular focus of quality PSM audits is the Process Hazard Analysis (PHA) and Management of Change (MOC) elements. For PHAs, we evaluated the availability of process safety information, implementation of the selected methodology, and criteria for making recommendations (typically using risk ranking).
Significant deficiencies in these areas were identified. Although prior audits had not identified any program deficiencies related to regulatory PSM requirements, a closer look at the quality of the procedures and training revealed significant issues that compromised the effectiveness of PHA and MOC programs. Recommendations were made to address these issues and improve the overall quality of these programs.