Episode 57 explains the PSM Compliance Audit requirement under OSHA’s Process Safety Management Standard (29 CFR 1910.119). Dr. Ayers breaks down what the audit is, why it matters, how often it must be done, and what leaders must do to ensure it actually improves process safety rather than becoming a paperwork exercise.
The core message: A PSM compliance audit is not about passing or failing — it’s about finding weaknesses before they become catastrophic.
A PSM compliance audit is a formal, systematic review of how well an organization is meeting each element of the PSM standard.
The audit must:
Evaluate every PSM element
Identify gaps, deficiencies, and non‑compliance
Document findings
Drive corrective actions
It is not optional — it is a regulatory requirement.
OSHA requires:
A compliance audit at least every 3 years
Retention of the last two audits (covering at least 6 years)
Dr. Ayers emphasizes that many organizations wait until the deadline, which weakens the value of the audit.
The episode stresses that the audit team must be:
Knowledgeable about PSM
Independent from the area being audited
Competent in process safety principles
Objective and willing to identify weaknesses
Teams often include:
Internal PSM experts
Operations personnel
Maintenance representatives
Third‑party auditors (optional but beneficial)
A PSM audit must evaluate all 14 PSM elements, including:
Process Safety Information (PSI)
Process Hazard Analysis (PHA)
Operating Procedures
Training
Mechanical Integrity
Management of Change (MOC)
Incident Investigation
Emergency Planning
Contractor Management
Hot Work
Pre‑Startup Safety Review (PSSR)
Compliance Audits (meta‑audit)
Trade Secrets
Employee Participation
The audit must verify both documentation and implementation.
Dr. Ayers highlights typical findings:
Outdated or incomplete PSI
PHAs not updated every 5 years
Operating procedures not reflecting current practice
Inconsistent training documentation
MOC processes not followed
Mechanical integrity gaps (e.g., overdue inspections)
Corrective actions not closed
Incident investigations lacking root cause analysis
These weaknesses often indicate systemic issues, not isolated errors.
The episode emphasizes that the audit is only valuable if findings lead to action.
Effective corrective action systems must:
Assign responsibility
Set deadlines
Track progress
Verify completion
Document closure
OSHA expects employers to address audit findings promptly.
Safety leaders must:
Ensure audits are conducted on schedule
Select qualified, objective auditors
Provide full access to information and personnel
Support honest, transparent findings
Prioritize corrective actions
Communicate results to affected employees
Use audits as learning tools, not blame tools
The episode stresses that a weak audit is worse than no audit, because it creates false confidence.
