What should a HSE Director audit when he visit a site

As an HSE Director auditing a site in Texas, you should evaluate several key areas to ensure compliance with OSHA standards and promote a safe working environment. Here are some key areas to consider:

1. Process Safety Management (PSM):

• Compliance Audits: Ensure the site has a trained individual or team to audit the process safety management system and program at least every three years 1, 5. The audit should evaluate the design and effectiveness of the PSM system and include field inspections to verify effective implementation [1].
• Audit Program Elements: Verify that the audit program includes planning, staffing, conducting the audit, evaluation and corrective action, follow-up, and documentation [2].
• Audit Team: Confirm that audit team members are selected for their experience, knowledge, and training, and are familiar with the processes and auditing techniques [2].
• Audit Execution: Ensure the audit includes a review of relevant documentation, process safety information, physical facility inspections, and interviews with personnel at all levels [2].
• Corrective Actions: Check that the site has a process for addressing deficiencies identified during audits, including planning, follow-up, and documentation [2].

2. Incident Investigation:

• Incident Investigation Process: Verify that the site has an in-house capability to investigate incidents that result in or could have resulted in a catastrophic release [3].
• Investigation Team: Ensure the incident investigation team is multi-disciplinary and trained in investigation techniques, including witness interviews, documentation, and report writing [3].
• Incident Reports: Confirm that incident investigation reports include the date of the incident, date the investigation began, a description of the incident, contributing factors, and recommendations [4].
• Corrective Actions: Check that the site has a system to promptly address and resolve incident report findings and recommendations, with documented resolutions and corrective actions [4].
• Report Review: Ensure that incident reports are reviewed with all affected personnel, including contract employees where applicable [4].

3. Emergency Preparedness:

• Emergency Action Plan: Ensure the site has an emergency action plan in accordance with 29 CFR 1910.38, including procedures for handling small releases [4].
• Employee Training: Verify that employees are appropriately trained in their emergency duties and responsibilities [3].
• Emergency Control Center: For medium to large facilities, check for the establishment and equipment of an emergency control center in a safe zone area [1].

4. Training Programs:

• Training Program Adequacy: Review all aspects of the training program, including content, frequency, and effectiveness [2].
• Employee Knowledge: Determine employees' knowledge and awareness of safety procedures, duties, rules, and emergency response assignments through interviews [2].
• Training Evaluation: Periodically evaluate training programs to ensure skills, knowledge, and routines are understood and implemented by trained employees [5].

5. Contractor Safety:

• Screening Process: Establish a screening process for hiring contractors who can perform job tasks without compromising safety and health [5].
• Injury and Illness Logs: Maintain a site injury and illness log for contractors to track work activities involving contract employees [5].
• Work Authorization: Implement a permit system or work authorization system for contractor activities [6].

6. Management of Change:

• Written Procedures: Establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures [7].
• Change Considerations: Ensure procedures address the technical basis for the change, its impact on safety and health, modifications to operating procedures, the necessary time period for the change, and authorization requirements [7].
• Employee Training: Inform and train employees, including maintenance and contract employees, whose job tasks will be affected by a change in the process prior to start-up [7].

7. Mechanical Integrity:

• Mechanical Integrity Program: Implement a mechanical integrity program to assure the continued integrity of process equipment [6].
• Equipment and Instrumentation: Identify and categorize equipment and instrumentation for inclusion in the program, including pressure vessels, storage tanks, process piping, relief and vent systems, and fire protection system components [6].
• Inspections and Tests: Perform inspections and tests on process equipment following recognized and generally accepted good engineering practices [8].

8. Hot Work Permits:

• Permit Issuance: Issue hot work permits for hot work operations conducted on or near a covered process [8].
• Fire Prevention: Document that fire prevention and protection requirements have been implemented prior to beginning hot work operations [7].

By focusing on these key areas, you can effectively audit the site's HSE management system and identify areas for improvement to ensure a safer workplace.