Virtual Compliance Audits

In the event government or internal company policies restrict access to the site and conducting an in-person three year compliance audit is not possible, a remote audit is an option. Proper preparation prior to the audit is key to a thorough and concise outcome.

Prior to the audit, gather all PSM programs and supporting documentation. If the site has been through a government audit document request, the data collection is similar. Review each element of the PSM and locate all documentation that proves adequate implementation of each element. A suggested list is as follows:

PSM/RMP Supporting Documentation & Records Review

  • Process Safety Information
    • Safety Data Sheets / Chemical Properties
    • Inventory Records / Control
    • Process Flow Diagram
    • Piping and Instrumentation Diagrams (with valves labeled)
    • Equipment lists
    • Review of equipment technical operating specifications (safe upper and lower limits, consequences of deviation, materials of construction, design codes & standards, etc.)
    • Review of safety systems (detectors, e-stops, ventilation, etc.)
    • Walkthrough to verify PSI
  • Process Hazard Analysis
    • Review of previous PHA Recommendations
    • Previous PHAs from startup until now
  • Operating Procedures
    • Initial Startup
    • Normal Operations
    • Temporary Operations
    • Emergency Shut Downs
    • Conditions Requiring Emergency Shut Down
    • Assignment of Shut Down Responsibility to Qualified Operators
    • Emergency Operations
    • Normal Shut Down
    • Startup Following a Turnaround or Emergency Shut Down
    • Annual SOP Review/Certification
  • Mechanical Integrity
    • Maintenance Records
    • Maintenance Procedures
  • Contractors
    • All contractors that work on or near the regulated processes
    • Contractor Packages (contractor training, OSHA 300 Logs, Evaluations, etc.)
  • Incident Investigations
    • Review of Incidents and Near Misses
    • Incident Investigation Reports
  • Employee Participation
  • Management of Change & Pre-Startup Review
    • Review of Process Changes
    • Completed MOC & PSSR Forms
  • Training
    • Evacuation Training Record
    • Hazardous Chemical Training Records
    • Training records for employees who perform above operating procedures (sign in sheets and means used to verify training was understood)
    • Initial Records
    • Refresher Records
  • Hot Work Permit
    • Completed hot work permits
  • Compliance Audits
    • Review of previous audit recommendations
    • Review of two most recent audit reports
  • Emergency Planning & Response
    • Review of procedures and contact information
    • Emergency Response Training Records (evacuation, HAZWOPER, critiques, etc.)
    • Coordination of ERP / EAP with fire department (correspondence, participation records, etc.)
  • Hazard Assessment
    • Worst & Alternative Case Scenarios
    • Previous Hazard Assessments from startup until now
  • Management System
    • Review of responsible parties
    • Organization chart
  • Risk Management Plan
    • EPA RMP Submittal


Supply all gathered information to the auditor to review. Once the information has been processed, the auditor will conduct one or several conference calls to settle any unanswered questions and/or to get clarification on any documents or records that may be confusing. The auditor may also request additional documentation if the initial information provided is lacking or inadequate.

An important component of the audit is the system walkthrough, which will need to be completed by in-house personnel. The auditor may request to see photographs of certain equipment or process areas to verify that actual onsite conditions are in accord with the PSM programs and procedures.  

Upon completion of the audit report, the auditor may hold a final conference call to review the audit findings, answer any questions from facility personnel, and wrap up any unresolved issues.