What Is Compliance Audits Under PSM?
Section 1910.119(o) requires employers to certify that they have evaluated compliance with the provisions of PSM at least every three years. The compliance audit must cover all 14 PSM elements and must verify that the procedures and practices developed under the standard are adequate and being followed.
The audit must be conducted by at least one person knowledgeable in the process. This does not mean the audit must be conducted by an outside consultant — internal audits performed by qualified personnel satisfy the requirement. However, the auditor cannot be the same person responsible for implementing the element being audited.
When the audit identifies deficiencies, those deficiencies must be corrected. Facilities that conduct audits, identify deficiencies, and fail to correct them are in a worse compliance position than those that never audited — because they have documented knowledge of violations and evidence that they chose not to act. OSHA inspectors always request the two most recent audit reports.
What the Standard Actually Requires
- 1Three-Year Frequency — Compliance audit must be completed at least once every three years. No exceptions.
- 2Coverage of All Elements — Audit must evaluate compliance with all provisions of 1910.119.
- 3Qualified Auditor — At least one auditor must be knowledgeable in the process. Auditors cannot be solely responsible for the element they are auditing.
- 4Written Report — A formal audit report must document findings — including deficiencies.
- 5Deficiency Resolution — Deficiencies identified must be corrected promptly and documented.
- 6Report Retention — Two most recent audit reports must be retained.
Common Violations OSHA Cites
These are the deficiencies inspectors most frequently document in Compliance Audits programs. Each can represent a separate citation.
Frequently Cited Violations
- Compliance audit not performed within three years of the previous audit
- Audit reports not retained — only one or zero prior reports available
- Audit conducted but deficiencies not corrected and not tracked for resolution
- Audit scope incomplete — covered only selected elements
- Auditor was responsible for the element being audited
- No audit report produced — verbal findings only
What Inspectors Look For
- Requesting the two most recent compliance audit reports immediately upon arrival
- Comparing audit findings against the current state of the PSM program to check resolution
- Reviewing the deficiency tracking log from prior audits for open items
- Checking the audit date against the three-year requirement
Consequences of Compliance Audits Failures
The compliance audit is specifically designed to provide early warning of PSM program deterioration before a catastrophic incident occurs. Multiple post-incident investigations have found that the issues that caused a major incident were known and documented in prior audits — but correction was deferred indefinitely.
Penalty Exposure — Compliance Audits
OSHA penalty range for Compliance Audits violations: $4,000-$15,625 per violation. Finding an overdue audit often triggers a broader, more intensive inspection. The audit violation itself may be a serious citation ($4,000-$15,625), but it frequently leads to discovery of willful violations in other elements.
Documents Your AUD Program Needs
An OSHA compliance inspection for Compliance Audits will typically request the following. Gaps in any of these areas may result in citations.
Required Documentation
- Two most recent compliance audit reports
- Audit deficiency tracking log with resolution dates
- Auditor qualifications documentation
- Audit schedule showing upcoming three-year frequency
- Corrective action records for prior audit findings
Related LOI Guidance
OSHA has clarified these specific questions about the Compliance Audits element through official Letters of Interpretation:
Get Compliance Audits Documents — Ready to Use
SafeGuard PSM provides OSHA-aligned Compliance Audits procedures, templates, and checklists that you can implement today. Written by PSM professionals. Formatted for actual field use.
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