Remote Auditing for PSM and RMP

OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Program (RMP) audits are critical for ensuring safety, compliance, and risk reduction in industrial processes. At times physical presence of auditors is not possible due to safety constraints, pandemics, or travel restrictions, in such circumstances remote auditing becomes essential.

This article will discuss how remote PSM/RMP audits can be effectively conducted using guidelines for remote auditing from ISO 9001 Auditing Practices Group (APG), International Accreditation Forum (IAF) MD4 and American Institute of Chemical Engineers (AIChE).

In this article, first we will talk about Remote Auditing in General and then discuss specifics of Remote PSM/RMP Auditing.

REMOTE AUDITING IN GENERAL

Benefits of Remote Auditing:

• Global Reach: Information And Communication Technologies (ICT) enables auditors to communicate with people worldwide, accessing a wide range of information and data.
• Cost and Time Savings: Remote audits reduce travel expenses, environmental impact, and travel time.
• Flexibility: Use of ICT also allows for the inclusion of expertise in an audit that otherwise might not be possible due to financial or logistical constraints.

General Recommendations:

• Awareness: All stakeholders should understand their roles, inputs, expected outputs, and risks/opportunities related to remote audits.
• Risk Assessment: Identify risks and opportunities associated with remote audit techniques (e.g., data security, communication challenges).
• Communication: Clear communication channels are essential for successful remote audits.
• Validation of ICT Tools: Ensure that tools used (e.g., video cameras, smart devices) are reliable and fit for purpose.

Here are the key points:

Audit Process Phases:

1. Audit Program: Define the scope, objectives, and schedule for remote audits.
2. Audit Planning: Plan activities, select appropriate ICT tools, and engage relevant personnel.

2. Priority Areas: Schedule audits for areas with recent changes or past non-conformities. Consider production cycles and seasonal activities.
3. Linked Processes: Plan audits around processes, not just standard clauses. Explore synergies and internal customer issues.
4. Risk-Based Approach: Higher Risk areas can be audited more frequently than low risk areas with proper documented justification and record keeping.
5. Audit Execution: Conduct remote interviews, document reviews, and virtual walkthroughs.
6. Audit Conclusion: Summarize findings, prioritize corrective actions, and communicate results.
7. Technology and Process Focus:
   • Virtual Platforms: Use reliable virtual meeting platforms for interviews and document sharing e.g. MS SharePoint.

REMOTE AUDITING PSM/RMP

Here are the key steps and considerations for effectively conducting remote PSM/RMP audits:

1. Preparation:

• Scope Definition: Clearly define the audit scope, identifying which PSM/RMP elements (e.g., process hazard analysis, mechanical integrity, management of change) will be assessed.
• Documentation Review: Gather relevant documents, including P&IDs, SOPs, incident reports, and previous audit findings.
• Communication: Schedule virtual meetings with relevant personnel, such as process engineers, operators, and management.

2. Technology and Tools:

• Virtual Platforms: Choose a reliable virtual meeting platform (e.g., Zoom, Microsoft Teams) for interviews and document sharing.
• Screen Sharing: Ensure participants can share screens to review documents together.
• Secure Connection: Use encrypted connections to protect sensitive information.

3. Interviews and Discussions:

• Process Walkthroughs: Conduct virtual walkthroughs with operators to understand processes and identify potential hazards.
• Structured Interviews: Ask open-ended questions during interviews and actively listen to responses e.g.:
  • Verify operating procedures knowledge by interviewing an operator
  • Verify process equipment details against a P&ID using photographs
  • Verify mechanical integrity of process equipment by asking inspection logs
• Behavioral Observations: Observe safety practices during virtual meetings.

4. Document Review:

This probably is the most important element of a remote audit.

• P&IDs and SOPs: Verify alignment with actual operations.
• Incident Reports: Analyze incidents to identify recurring issues.
• Audit Checklists: Use predefined checklists for consistency.

5. Risk Assessment:

• PHA Review: Evaluate process hazard analyses (PHA) remotely. Discuss findings and recommendations.
• Risk Matrix: Assess risk levels based on severity and likelihood.

6. Mechanical Integrity:

• Equipment Inspection: Review inspection records and maintenance logs.
• Non-Destructive Testing: Discuss NDT results and follow-up actions.

7. Management of Change (MOC):

• MOC Process: Evaluate how changes are managed virtually. Review MOC forms and approvals.
• Communication: Assess communication channels for MOC updates.

8. Emergency Preparedness:

• Emergency Plans: Review emergency response plans and evacuation procedures.
• Scenario Discussions: Simulate emergency scenarios during virtual meetings.

9. Contractor Management:

• Contractor Audits: Assess how contractors are managed remotely.
• Safety Training: Verify contractor safety training records.

10. Closing and Reporting:

• Findings and Recommendations: Summarize audit findings and prioritize corrective actions.
• Management Presentation: Present findings to management via virtual meetings.
• Follow-Up: Schedule remote follow-up audits to track progress.

References & Resources Used:

1. ISO 9001 APG Guidance on Audit Planning
2. ISO 9001 APG Guidance on Audit Reports
3. ISO 19011:2018 Annex A1
4. IAF MD4 Principles on Remote Assessment
5. AIChE

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Please contact us if you are interested in having PSM or RMP consulting or auditing of your facility in-person or remotely: