Auditing
An internal annual, corporate triennial, statutory, and insurer audit programme with finding closure governance
What this element is and why it matters
Auditing is the assurance mechanism that proves PSM elements are not merely designed but actually working. The element maps to OSHA PSM 1910.119(o) triennial certification, CCPS RBPS Element 19, the ISO 19011 audit principles, and the corporate, insurer, and statutory audit cycles that overlay site level execution. Modern programmes bring together cadences across the internal annual audit, the corporate triennial audit, OSHA and MSIHC statutory audits, third party certification such as ISO 45001 and RC14001, and insurer surveillance, and our team weaves them into one coherent programme.
Individual significance for organisations
Auditing is how an organisation discovers what it does not know about its own performance. Sites that audit rigorously identify drift before it shows up as incidents, while sites that audit superficially miss the patterns that matter. The element is also where independent perspective enters, because without external eyes the system simply optimises around its own blind spots.
Contribution to Risk Based Process Safety (RBPS)
Auditing is the assurance layer over every other RBPS element. It validates Compliance with Standards (Element 2), tests PHA quality (Element 7), examines MOC discipline (Element 13), checks training records (Element 12), and verifies asset integrity programmes (Element 10). Audit findings feed Measurement and Metrics (Element 18) and Management Review (Element 20). Element 19 is the self diagnostic capability of the whole system.
What compliant execution looks like
How we implement this element
A focused six step methodology calibrated to deliver auditing as a working capability rather than a documented compliance artefact.
We map the audit cadences across the internal annual audit, corporate triennial audit, statutory audits per requirement, third party certification, and insurer surveillance.
We specify lead auditor competency per ISO 19011 and CCPS, ensure the auditor is independent of the area being audited, and set the training and certification requirements.
For each RBPS and OSHA PSM element we build an audit protocol covering sample size, evidence requirement, interview protocol, and scoring criteria.
We run a multi day on site audit with document review, walk down, operator and supervisor interviews, and a leadership debrief.
We categorise findings by severity as critical, major, or minor, assign an owner and target close out, and track them in the corrective action database.
We run an annual programme review covering audit finding repeat rate, closure cycle metric, and audit quality against the incident trend, integrated with corporate HSE.
Element implementation flow chart
A decision gated workflow that shows the actual sequence of activities from initiation through steady state operation, with key decision points highlighted.
What we produce
- An audit programme charter with a multi cadence design
- An auditor competency and independence framework
- An audit protocol per RBPS and OSHA PSM element
- A field audit execution plan
- A finding closure database and tracking dashboard
- An annual audit programme effectiveness review
Where execution fails
- Tick box audits that find only what the auditors expect to find
- Findings filed but never closed
- Corporate audits that are never integrated with site level work
- Auditor competency that sits below the rigour the element demands
Codes this element is built on
Explore related elements in this framework
Risk Based Process Safety (RBPS) full element index
Talk to us about implementing Auditing
We can scope this element implementation against your facility, regulatory context, and existing management system maturity, then integrate it with the other Risk Based Process Safety (RBPS) elements you already operate.