Service · Compliance Audits

PSM Compliance Audits
That Find What Matters.

Every PSM-covered facility must audit its program at least every three years. A good audit checks more than whether the documents exist. It checks whether the practices on the floor match them. SafeGuard PSM audits all 14 elements, with auditors who have run these programs from the inside.

What the Rule Requires

Compliance Audit Requirements

29 CFR 1910.119(o) for OSHA PSM, and 40 CFR 68.58 (Program 2) and 68.79 (Program 3) for EPA RMP, share the same five core requirements.

Every 3 years

Certify that you have evaluated compliance at least every three years, to verify procedures and practices are adequate and being followed. [(o)(1)]

Knowledgeable auditor

At least one person knowledgeable in the process. [(o)(2)]

Written report

A report of the audit findings. [(o)(3)]

Response and correction

Promptly determine and document a response to each finding, and document that deficiencies were corrected. [(o)(4)]

Keep the last two

Retain the two most recent compliance audit reports. [(o)(5)]

All elements

The audit covers the provisions of the standard: every element, not a sample of them.

RMP third-party audits (2024 rule). Under 40 CFR 68.59 and 68.80, the next compliance audit must be a third-party audit after an RMP-reportable accident, or when the implementing agency requires one. Third-party auditors must meet competency and independence criteria, and the facility must issue a findings response report within 90 days. Compliance date: May 10, 2027. EPA's 2026 proposal (91 FR 8970) would remove or narrow third-party audits; it is not final. In California, Cal/OSHA §5189 has no audit subsection of its own, but CalARP Programs 2–4 do; see our California PSM page.

How We Audit

Documents, Field, and People

Step	What happens
1. Scope and protocol	Which processes, which regulations (PSM, RMP, state programs), and the audit protocol for all 14 elements.
2. Document review	PSI, PHAs and recommendation closure, procedures and annual certifications, training records, MI inspection records, MOCs, PSSRs, incident investigations, contractor files, hot work permits, the emergency plan, and the employee participation plan.
3. Field verification	Walk the unit: do the P&IDs match the plant? Are relief devices as documented? Are procedures at the point of use and followed?
4. Interviews	Operators, maintenance staff, contractors, and supervisors. Practices are verified with the people who do the work.
5. Report	Findings tied to the specific regulatory paragraph, each with clear evidence, plus observations and good practices.
6. Response support	We help you document a response to each finding and track corrections, since (o)(4) requires both.

Where Audits Find Problems

What We Look At Hardest

Mechanical integrity

Inspection and testing on schedule, following good engineering practice, with deficiencies corrected before further use or managed safely [1910.119(j)].

PHA recommendations

Recommendations without documented resolution, missed schedules, and revalidations that re-signed the old study without updating it.

PSI and MOC

P&IDs and relief design that no longer match the plant, and changes made without an MOC or with PSI never updated afterward.

Audit Due, or Want a Pre-Inspection Check?

Tell us your facility and your last audit date. We'll scope an audit that meets the rule and gives you findings you can act on.

Talk to Us PHA & HAZOP Facilitation Free PSM Assessment

Sources

OSHA, 29 CFR 1910.119(j), (o): eCFR
EPA, 40 CFR 68.58, 68.59, 68.79, 68.80, and 68.10 (compliance dates): eCFR · EPA proposed rule, 91 FR 8970 (Feb 24, 2026): Federal Register
Not legal advice. Confirm requirements against the current regulations.

PSM Compliance AuditsThat Find What Matters.