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Our Solutions: Consulting

PSM – Gap Analysis and Compliance Audit

Understanding PSM Gap Analysis and Compliance Audit

Gap Analysis

One of the most challenging aspects of process safety management is the attempt to interpret and convert specific safety elements into practices that are unique to a business. It is not uncommon to see one organization interpret PSM elements differently than another organization. Some companies, however, tend to interpret the regulation in a minimalistic manner or may simply limit their approach to cover basic compliance risks and legal regulations.

The gap analysis will aid you in identifying and evaluating your existing process safety management systems to adhere to regulatory compliance. A PSM Gap analysis is a systematic series of assessments to identify gaps and problem areas associated with the elements of risk-based PSM programs embedded in the operation, design, and maintenance of a process system.  

A process safety gap analysis is the first step in understanding the level at which a facility is currently performing when it comes to process safety. In essence, it is a series of risk assessments that aim to identify gaps and problematic areas that can be associated with uncertainty across operations, design, and facility maintenance.

Our gap analysis is based on CCPS Guidelines for Risk-Based Process Safety and OSHA PSM (29 CFR 1910.119)

Gap Assessment (20 Elements of Risk Based Process Safety):

  • Foundational Block: Commit to Process Safety
    • Process safety culture
    • Compliance with standards
    • Process safety competency
    • Workforce involvement
    • Stakeholder outreach

 

  • Foundational Block: Understand Hazards and Risk
    • Process knowledge management
    • Hazard identification and risk analysis (HIRA)

 

  • Foundational Block: Manage Risk
    • Operating procedures
    • Safe work practices
    • Asset integrity and reliability
    • Contractor management
    • Training and performance assurance
    • Management of change
    • Operational readiness
    • Conduct of operations
    • Emergency management

 

  • Foundational Block: Learn From Experience
    • Incident investigation
    • Measurements and metrics
    • Auditing
    • Management review and continuous improvement

Compliance Audit

A documented periodic audit of compliance with the 14 elements of Process Safety Management is required at least every three years. Employers must certify that they have evaluated compliance with the provisions of PSM to verify that the procedures and practices developed under the standard are adequate and being followed.

What is the difference between a Gap Analysis and a Compliance Audit?

Where a Gap Analysis can give a high-level review of your PSM program, the periodic audit dives deeper into each of the elements, looking at procedures, documentation, employee experiences, and site walkthroughs to create a report of the findings of the audit, including a list of action items.

Audit (14 Elements of PSM):

  • Employee Participation
  • Process Safety Information
  • Process Hazard Analysis
  • Operating Procedures
  • Training
  • Contractors
  • Pre-Startup Safety Review
  • Mechanical Integrity
  • Hot Work Permit
  • Management of Change
  • Incident Investigation
  • Emergency Planning and Response
  • Compliance Audits
  • Trade Secrets

The Sigma-HSE Advantage

Sigma-HSE has the required resources, knowledge, and experience to undertake an in-depth gap assessment to cover employees and non-employees across process industries.

 

Using applied knowledge and implementing best practices, our actionable insights determine what practicable recommendations and control measures should be made for your company to optimize safety and reduce risk to your people, your businesses, the workplace, and the environment.

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If you find yourself asking, ‘Do I need a Gap analysis or PSM compliance audit?’, connect with us today. Our experts can answer any preliminary questions you may have.

 

For businesses in the EU or UK, or for those wishing to comply with DSEAR/ATEX Directives, please click here to find out more on our dedicated DSEAR/ATEX pages. 

PSM – Gap Analysis and Compliance Audit : Enhancing safety through targeted improvements.

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