Audits are a fundamental feature of all successful management programs. It is vital that line managers know how they are performing, and senior management needs a means of checking that all the rules and standards are being followed.
With regard to process safety the phrase, “There is always news about safety, and some of that news will be bad” is frequently heard. Audits are needed in order to identify that bad news.
Types of Audit
Broadly speaking, there are two types of audit: formal audits and relatively informal reviews or assessments (with a good deal of overlap between the two).
A formal audit is primarily a compliance exercise. The auditor is provided with an objective standard (which could be a regulation or an internal company document). He or she then determines if the facility being audited complies with the requirements of that standard. A review or assessment is less formal. The reviewer evaluates the facility’s performance, and, based on his or her experience, provides opinions as to the quality of what he sees.
All process safety management programs must be audited on a regular basis — typically every three years. The auditor evaluates conformance with the requirements of the regulation.
For example, the following statement is taken from the OSHA standard to do with operating procedures.
The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting <an> initial startup;
Given this standard an auditor could point to a compressor and say to a technician, “Show me the procedure for starting this compressor.” If the technician produces that procedure in a timely manner, if he can demonstrate how to follow the steps of the procedure, and if the procedure is up to date then the audit requirement is satisfied.
Moreover, if the auditor does find a deficiency then is not required to come up with a solution. His task is limited to finding gaps between “what is” and “what should be”. An auditor’s job is to objectively uncover deviations from the standards — no more, no less. The auditor needs to be skilled at conducting audits, and he or she certainly needs to have a working knowledge as to how energy or process facilities work. But he does not need to be an expert in the matter being audited.
An audit demonstrates that a facility is or is not following the requirements of an external standard. However, the facility management may be looking for additional insights and guidance as to how they can improve their process safety program. Moreover, audits that are limited to an evaluation of safety programs provide little assistance when looking at related management challenges, such as increasing production or improving profitability.
More fundamentally, the philosophy behind process safety programs is that they are performance-based rather than being compliance activities. So many auditors will supplement their findings with insights based on their own experience and knowledge. But, when they do so, they are strictly speaking not actually auditing — they are conducting an assessment or review.
Returning to the compressor startup procedures just quoted, a reviewer or assessor might ask questions such as,
- Is this procedure too long?
- Is it too short?
- Can it be used outside at night in the pouring rain?
- Is it written at the correct grade level?
- Have the instructions from the compressor manufacturer been incorporated into the startup procedures?
- And — the most important question of all — does anyone actually use this procedure, or does it sit on a shelf or a hard drive quietly gathering dust?
There are no right or wrong answers to these questions — except for maybe the last one. One person may consider the procedure to be the right length, another may disagree. Such a disagreement, as long as the parties remain polite to one another, is healthy. It forces everyone to examine the usefulness and relevance of the procedures and to determine if they are actually helping to make the facility safe and profitable. The essential point is that
Process Safety Assessments
We are developing a set of Process Safety Assessment checklists. It must be stressed that use of these checklists is not intended to replace formal audits. They are intended to supplement the audits.
As time permits, we will publish a set of ebooks — one for each element of process safety management. The ebooks will consist of sets of open-ended questions (audit questions are usually closed, i.e., they call for a “Yes” or “No” answer.)
The first ebook in this series is likely to be Prestartup Review Assessment. It currently has 10 chapters, each of which contains many questions. The chapters are:
- Startup Plan
- Piping and Valves
A Table is provided for each question. It consists of the following parts:
- A question number.
- The question itself.
- Space for a written response.
- Guidance and background to do with that question.
An example is provided below for the first question in Chapter 1. A representative response — in italics — is provided.
|Question||Do the operations and maintenance teams understand that they are the customers of the modified facility and that the review gives them full authority not to accept the facility in its current state?|
|Response||Discussions indicate that managers in operations and maintenance do not always realize that they have the authority to stop a facility from being started if they think that it could be unsafe, even though regulations, such as the Pre-Startup Safety Review rule from OSHA, back up the managers with the force of law.|
|Background||A Prestartup Review provides a breathing space for everyone involved in a project. In particular, it gives the operations and maintenance teams to check that what has been delivered to them is, in fact, what they expected to receive.|