Audits & Incident Investigation

Process safety compliance audits

OSHA PSM and EPA RMP require compliance audits at least every three years, conducted by at least one person knowledgeable in the process, with findings documented and deficiencies promptly addressed. A good audit does more than satisfy that requirement: it tests whether the program actually works in the field.

We offer audits at several levels of depth:

Our audit approach

1. Protocol and sampling plan

   Agree scope, protocol and the records and field areas to be sampled.

2. Document review

   Review programs and a representative sample of records: PHAs, MOCs, PSSRs, inspection records, training and investigations.

3. Interviews and field verification

   Talk with operators, maintenance staff, engineers and contractors; walk the unit to test what documents say against what people do.

4. Findings and close-out meeting

   Present findings with evidence and their significance, so there are no surprises in the report.

5. Report and action planning

   A report that distinguishes regulatory deficiencies from improvement opportunities, with a practical action plan.

Incident and near-miss investigation

PSM requires investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release, beginning no later than 48 hours after the incident. RMP has parallel requirements, and the 2024 RMP amendments added root cause analysis requirements for certain accidents and near misses.

We can lead an investigation, support your internal team, or provide independent review of a completed investigation. We follow a structured process: secure and collect evidence, establish the timeline, identify causal factors, determine root and contributing causes, and develop recommendations.

Getting to root causes

Investigations that end at "operator error" or "equipment failure" rarely prevent recurrence. Effective root cause analysis asks why the error was possible and why the failure was not detected, and looks at the management systems behind them — design, procedures, training, maintenance, staffing and change management.

We use structured techniques appropriate to the event, such as timelines and causal factor charting, fault trees, barrier analysis, and systems-oriented methods that consider organizational and human factors.

From findings to action

• Recommendations that target root causes, not just symptoms
• Clear ownership, due dates and completion criteria
• Verification that completed actions are effective
• Lessons shared across similar units and sites
• Trending of findings to reveal systemic weaknesses

Frequently asked questions