(111b) Addressing Common PSM Audit Findings on Operating Limits and Safe Limits

Process safety audits are conducted for three main reasons: (1) feedback on process safety program implementation and effectiveness to identify potential improvement opportunities for improved performance, (2) compliance with applicable process safety regulations such as the U.S. OSHA 29 CFR 1910.119 Process Safety Management (PSM) standard, the U.S. EPA 40 CFR 68 Risk Management Program (RMP) rule, and other similar federal, state and/or local regulations, and (3) adherence to any internal company process safety programs/requirements. If a facility has a process covered by the above OSHA/EPA regulations, compliance audits must be conducted every 3 years. Since the OSHA standard was promulgated in 1992, this means that facilities in existence at that time are approaching having conducted 10 compliance audits. Newer processes obviously have had fewer audits, but a review of recent audit findings suggests certain issues continue to be commonly identified. This paper addresses some of the most frequent audit findings observed, specifically related to operating limits and safe limits and the associated consequences of deviations. Guidance is also provided on how these findings can be avoided through appropriate design and implementation of limits tables.