Auditing Under Pressure: Techniques for Compliance Auditing of Pressure Relief Systems

Pressure relief systems are commonly considered as part of compliance audits for processes covered by the OSHA PSM standard (OSHA 1910.119: Process Safety Management of Highly Hazardous Chemicals (8 FR 9313)) and the EPA Risk Management Plan (40 CFR 68, Subpart G). Their design documentation is a requirement a requirement of the Process Safety Information (PSI) element of these standards, and their proper inspection and testing is a requirement of the Mechanical Integrity (MI) element of these standards. This paper will evaluate the specific language of the above standards to provide guidance regarding their application to pressure relief systems and will discuss techniques for the evaluation of pressure relief systems within the context of a compliance audit. Additionally, this paper will provide examples of compliant documentation regarding pressure relief systems, as well as examples for documentation for which compliance auditors should generate findings.