PT Notes

OSHA RFI - Changes to Compliance Audit Requirements

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On December 3, 2013, the U.S. Occupational Safety and Health Administration (OSHA) announced a request for information (RFI) seeking public comment on potential revisions to its Process Safety Management (PSM) standard. Multiple issues were addressed in the RFI.

One issue deals with revising the PSM standard to require third party compliance audits. Employers are required to audit the PSM program in their facilities for compliance every three years. The standard requires that the audits be conducted by at least one person knowledgeable in the process. However, the standard does not require employers to use a third party in conducting the compliance audits.

OSHA has noted that the Center for Chemical Process Safety (CCPS) has stated, "Third party auditors (typically, consulting companies who can provide experienced auditors) potentially provide the highest degree of objectivity." OSHA also noted that the Safety and Environmental Management System (SEMS) standard from Bureau of Safety and Environmental Enforcement (BSEE) requires audits conducted by an independent third party, subject to approval by BSEE, or by designated and qualified personnel if the employer implements procedures to avoid conflicts of interest. In addition, revisions to the standard require by June 4, 2015 that the audit team leader be independent and represent an accredited audit service provider.

Also, OSHA is also seeking comment on increasing the required frequency of compliance audits and requiring specific timeframes for responding to deficiencies found in the compliance audit process.

OSHA has posed these questions on these issues in the RFI:

1. Does your facility use a third party for conducting compliance audits?
2. Please provide any data or information on workplace accidents, near misses, or other safety related incidents that could have been prevented or minimized by more effective compliance audits conducted for operations covered by the PSM standard. Were the ineffective compliance audits conducted by in house staff or a third party?
3. Would revising the PSM standard to require employers to use a third party for compliance audits prevent worker injuries and fatalities? What would be the economic impacts of revising the standard in this way (e.g., typical consultant fees, additional work hours required, special circumstances involving small entities, etc.)?
4. Should OSHA revise the PSM standard) to require employers to use compliance auditors (internal or third party) with certain minimum credentials or certifications? If so, what minimum credentials or certifications should the Agency require? What burden might this place on small businesses?
5. Should OSHA revise the PSM standard to require a compliance audit frequency other than every three years?
6. Would revising the PSM standard to require employers to respond to deficiencies found in the compliance audit within certain timeframes prevent worker injuries and fatalities? What would you consider to be an appropriate timeframe?

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Federal Register notice 

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