14 PSM Elements
13. Compliance Audits
Employers must conduct a PSM compliance audit at least every three years to verify that PSM procedures meet OSHA requirements and are being followed. Audits must be led by at least one knowledgeable person—more for complex processes—and should be impartial and skilled in audit techniques.
Audits involve planning, reviewing documents and procedures, inspecting the process, and interviewing employees. A well-designed checklist helps ensure all PSM elements are evaluated. The auditor reviews training programs, observes work practices, and identifies deficiencies.
All findings must be documented, including needed corrective actions or valid reasons for no action. Management must review audit results, set priorities, assign responsibilities, and implement corrections—using Management of Change (MOC) when required. Many employers use a unified system to track findings from PHAs, incident investigations, and audits.
Examples: A gas plant audit identifies gaps in MI inspections for compressors, leading to corrective actions and retention of reports.
14. Trade Secrets
The PSM standard requires employers to provide full access to all necessary process safety information (PSI) and documentation—even when the information involves trade secrets. This ensures that employees, contractors, and PHA team members can adequately evaluate process hazards and make informed safety decisions. Although companies may protect proprietary information through confidentiality agreements, they may not withhold information required for compliance with PSM.
In the oil and gas industry, for example, catalyst formulations, proprietary process technologies, or specialized treatment chemicals may be considered trade secrets. Even so, this information must be made available to those conducting Process Hazard Analyses (PHAs), writing operating or maintenance procedures, or performing other PSM-related tasks. Confidentiality agreements can be used to safeguard intellectual property while still ensuring workers and PHA teams have the data needed to evaluate hazards such as reaction kinetics, degradation mechanisms, temperature limits, and compatibility issues.
Examples: In petrochemical plants, employees access reactivity data for olefins crackers under agreements, ensuring full PSM implementation.
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7-8. How often must employers conduct a PSM compliance audit?
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