This Safety Moment discusses the distinction between Process Safety Assessments and Process Safety Audits. It provides guidance to do with the development of Assessment protocols.
Audits are a fundamental feature of all successful management programs. Line managers need to 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.
For these reasons, most process safety programs require that the system be audited on a regular basis, say once every three years.
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 such as a regulation, an industrial code or an internal company document. He or she then determines if the facility being audited complies with the requirements of that standard. The audit is fundamentally a ‘Yes/No’ exercise. Either the facility is in compliance, or it is not.
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 and effectiveness of the facility’s program and its implementation.
Audit protocols are built around objective standards provided by an external authority such as a government agency or industrial standards body. 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 piece of equipment such as a compressor and say to the technician who operates it, “Show me the procedure for starting this compressor.” If the technician produces that procedure in a timely manner, then demonstrates how he or she follows the steps of the procedure, and can show that the procedure is up to date, then the audit requirement is satisfied.
If the auditor does find a deficiency he or she is not required to come up with a solution. His task is limited to finding gaps between “what is” and “what should be”; 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. In this example, the auditor does not need to know how compressors work.
In practice, 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.
The facility's management may be looking for deeper insights than those provided by a formal audit. They may want to know how they can improve their program and its implementation. In the case of the example to do with starting the compressor, the auditor’s report may say that the operating procedure meets the standards that are being followed. However, management may be aware that there have been a number of operational upsets to do with compressor startups, and that some of those upsets can attributed to inadequate procedures. Therefore, they look to the assessor to identify where the problems lie, and how improvements can be made.
Management may also be looking for help in areas that are not directly to do with safety. For example, the facility may be spending too much money maintaining compressors. Management would like advice as to how these costs can be reduced, including better ways of starting the compressors at the site.
More fundamentally, the philosophy behind process safety programs is that they are performance-based; compliance with external standards are now what these programs are really about.
A reviewer can help the facility management by reviewing what other companies and organization, do, and coming up with best practices.
Continuing with the example of the compressor startup procedures, 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 comprehension 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 on a hard drive quietly gathering dust?
There are no right or wrong answers to these questions (apart from 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, 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. There are no right or wrong answers.
The essential point is that the assessor’s opinions and suggestions are invited and expected. He or she is considered to be an expert on the matter in hand, so his opinion is an important part of the discussion.
The assessor may also provide a ranking or score to his or her findings. The scoring system may look something as follows:
- ‘0’ — Missing / Not Acceptable
- ‘1’ — Unsatisfactory / Poor
- ‘2’ — Adequate
- ‘3’ — Good
- ‘4’ — Excellent
- ‘N/A’ — Not applicable