The PSM standard requires employers to certify that they have evaluated compliance at least every three years and retain the two most recent compliance audit reports. When conducting a PSM inspection, OSHA will ask for a copy of the two most recent compliance audit reports. OSHA will attempt to use one or both compliance audit reports as a basis for issuing citations and penalties, particularly if a finding has yet to be corrected. It is crucial, therefore, that a compliance audit report contain findings of violations of the PSM standard, not findings of non-compliance with best practices in the industry. Yet leading PSM experts throughout the country continue to mistakenly equate best practices with findings of non-compliance with the PSM standard, which can expose an employer to a significant legal risk. This presentation will discuss how to minimize that risk and at the same time uncover both findings of noncompliance and best practices.