Every three years, companies in the process industries must perform a compliance audit for their Process Safety Management (PSM) systems and Risk Management Programs (RMP). Many companies turn to third parties for assistance in conducting their PSM / RMP compliance audits in order to gain an outside perspective regarding implementation of PSM and RMP practices at their facility. However, companies often focus on the wrong factors in making a decision on selecting a third-party auditor.
Common decision factors include:
- Overall cost of using a third-party auditor. Naturally, cost is always a consideration, as companies don’t want to pay more than necessary.
Cost is an important factor but should not be the overriding factor in making a decision. Some companies choose the cheapest option for various reasons. However, often the cheapest option involves cutting corners, not conducting a detailed review for each process safety element, or using an auditor who lacks competence. “You get what you pay for” is true in almost every aspect of life and that applies to process safety audits.
Some companies have policies in place that prevent them from selecting the lowest cost option for a service or product because the quality may not be sufficient. That is the sensible route to take in selecting third-party process safety auditors since poorly performed audits can have devastating results for process facilities.
- Experience of the auditor with the company’s specific type of processes. Often, this is one of the biggest considerations.
The role of an auditor is to make an unbiased assessment of the facility’s degree of compliance with the PSM and/or RMP regulations. Too much knowledge of a process can predispose the auditor’s thought process on what they should review during the audit. An auditor with little to no knowledge of the process being reviewed often views things through a different lens than someone with intimate process knowledge. It is better to have an auditor with a wide range of process experience, across multiple industries, and for many different types of process.
- How quickly an audit report can be issued. Frequently, this is a top concern.
Companies should focus on the level of detail and overall quality of an audit report, rather than how quickly they can receive it after the study. It is important to get started on audit action items quickly, but the action items should be based on a high-quality audit if gaps are to be closed appropriately. That’s not to say reports should take months to assemble or that regulatory deadlines should not be met. However, if a report is reviewed by regulators or becomes an exhibit in litigation after an incident, you are going to want a high-quality product that went through proper quality assurance reviews, and how quickly you received it will not matter.
- Proximity of the auditor to the facility. It can help to keep travel expenses down.
Again, trading off costs against quality for a PSM/RMP audit is a decision that will be regretted.
The most important factor to consider is the competency of the PSM/RMP auditors, although often this is not given the attention it deserves. Process safety auditors should be certified to ensure their competency. PSM/RMP audits require not only auditing skills but also detailed knowledge of the performance-based process safety regulations. Certification ensures that auditors meet a defined standard of competency through education, experience, practice, training, and knowledge to ensure quality audits are performed.
Does your company use third-party process safety auditors? Are you considering competency when selecting auditors for your triennial PSM / RMP compliance audits? Are they certified?