Process Safety Management (PSM) Audit: What Inspectors Look For

Process Hazard Analysis (PHA)

Inspectors will scrutinize your PHA first. Is it current (revalidated within the 5-year cycle)? Was it conducted by a qualified, multidisciplinary team? Most critically, they'll examine your system for tracking and closing PHA recommendations. Open recommendations from years-old PHAs are a major red flag.

Mechanical Integrity

This is a documentation-heavy element. Inspectors demand proof that critical process equipment — pressure vessels, storage tanks, piping systems, relief devices, and control systems — is being inspected, tested, and maintained on a defined schedule by qualified personnel. Missing or incomplete records are the most common finding.

Management of Change (MOC)

MOC is one of the most commonly cited PSM elements. Inspectors look for evidence that your MOC process is robust and that all recent changes were properly assessed for safety impact before the change was implemented. They'll ask for recent examples and review the complete documentation package.

Operating Procedures and Training

Are your operating procedures accurate, certified annually, readily accessible to operators, and do they cover emergency shutdown procedures? Inspectors will review training records and may interview operators to verify they understand the procedures.

Hot Work and Contractor Management

Hot work permitting and contractor safety management are frequent sources of incidents and citations. Ensure your hot work permits include fire watch requirements and pre-work hazard assessments, and that contractors are properly screened and supervised.