Beyond Compliance Auditing: Drill ‘til you find the pain points and release the pressure!

by Laura Ankrom, P.E. & Kathy Shell, P.E.

In Failure to Learn: the BP Texas City Refinery Disaster, the author, Andrew Hopkins, explores the importance of senior managers using auditing as a tool to identify “unrecognized problems that may be lurking beneath the surface” (Hopkins, 2010, p. 114). He also goes on to state that auditors “will not set out to sample the organization. Rather, they will use their expert knowledge to zero in on areas where things might be going wrong” (Hopkins, 2010, p. 115).

Building on this concept, the authors of this paper will look beyond traditional OSHA PSM and USEPA RMP regulatory compliance auditing to explore the value of drilling down around the process safety lifecycle; locating the pain points; and releasing the pressure on the system. Compliance auditing has historically provided a “check-the-box” approach to meet regulatory requirements imposed by OSHA and USEPA. Regulatory compliance, however, is no guarantee of the prevention of major accidents. There is still a need to identify hazards, understand and manage risks. Today’s auditors need to determine how to systematically identify the root cause of the “pain points” that will foster conversations around releasing the “pressure” on existing practices to achieve a vibrant integrated process safety management system.

Industry standards, such as ANSI/ISA 84.00.01 and IEC 61511, continue to drive the evolution of functional safety and meeting these requirements go far to demonstrate that a company has reduced risk to a tolerable level. The ANSI/ISA/IEC lifecycle approach actually quantifies the value of an integrated process safety program by assigning a numerical value to risk and assessing the effectiveness of the independent protection layers (IPLs) at meeting safety integrity targets. There is a growing realization in industry that having a healthy process safety management program in place is essential in meeting the full intent of IEC 61511 and ISA84.91.

The authors will present a drill down audit methodology that focuses on the organizational interfaces and the related management system procedures and practices used to meet the defined safety integrity requirements of both instrumented and non-instrumented IPLs. The approach utilizes a hazard scenario-based drill down audit methodology to expose the issues and the sources of the “pain” by digging deep into the management system processes around process hazard analysis, process safety information, mechanical integrity, operating procedures and management of change. When exposed in this manner, there is an audit trail that provides a basis for revising the work flow to “release the pressure” and accomplish the risk management objectives going forward.


Keywords: Verification, Auditing, Compliance Auditing, USEPA Risk Management Program, OSHA Process Safety Management, Process Safety Lifecycle, ISA84.91, IEC 61511, Independent Protection Layer (IPL)


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