2.13 Compliance Audits
29 CFR 1910.119 (o)
Employers shall certify that they have evaluated compliance with the provisions of this section at least every
three years to verify that the procedures and practices developed under the standard are adequate and are
The compliance audit shall be conducted by at least one person knowledgeable in the process.
A report of the findings of the audit shall be developed.
The employer shall promptly determine and document an appropriate response to each of the findings of the
compliance audit, and document that deficiencies have been corrected.
Employers shall retain the two (2) most recent compliance audit reports
The purpose of the audit element is to ensure that the PSM program is operating in an integrated
and effective manner. DOE contractors must conduct internal audits or self assessments for
compliance with the PSM Rule at least every 3 years to determine the degree to which plans and
programs have been implemented.
Audits are a tool to help contractors identify PSM weaknesses and develop recommendations.
The audit team should provide an independent assessment of the degree of compliance with the
PSM Rule, even though one member may by necessity be involved in the operation of the
Audits have two major objectives. The first is to assess whether the management system in place
adequately addresses all elements of the PSM Rule. This part of the audit attempts to discover
fundamental design deficiencies that could compromise the effectiveness of a PSM program. The
second objective is to assess whether the management system has been adequately implemented
for every facility or process. Deficiencies discovered during this part of the audit may indicate a
need for better communications or training, or may signal fundamental management problems.
Corresponding DOE Programs and Requirements
DOE G 414.1-1A, Management Assessment and Independent Assessment Guide, provides
nonmandatory guidance for satisfying requirements contained in DOE O 414.1A Chg 1,
QUALITY ASSURANCE, and 10 CFR Part 830 Subpart A. DOE O 231.1A contains safety and
health reporting requirements which provide indicators of program performance that can be used
to highlight safety management weaknesses which should be examined.
PSM audits can be encompassed within existing internal self-assessment and corrective action
tracking programs within DOE. DOE contractor self-assessments are implemented in various
ways and by different organizational groups under DOE safety appraisal programs.
Reports of internal audit findings must be written, and DOE contractors must document
responses to the findings and certify that the deficiencies have been corrected.