Compliance Audits - doe-hdbk-1101-20040106

DOE-HDBK-1101-2004

2.13 Compliance Audits

29 CFR 1910.119 (o)

(1)

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

being followed.

(2)

The compliance audit shall be conducted by at least one person knowledgeable in the process.

(3)

A report of the findings of the audit shall be developed.

(4)

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.

(5)

Employers shall retain the two (2) most recent compliance audit reports

Intent

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

process.

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.

Documentation Requirements

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.