Edition No. 14

Process Safety Management – Is Your Program Integrated into Your Business Processes?

The Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM) emphasizes the management of hazards associated with highly hazardous chemicals. In addition, it establishes the requirement for a comprehensive management program that integrates technologies, procedures, and management practices for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Similarly, the Environmental Protection Agency (EPA) requires applicable companies to develop a Risk Management Program (RMP) to reduce the chemical risk associated with facilities using extremely hazardous substances. In the State of California, the California Accidental Release Prevention (CalARP) Program is a merging of the federal and state programs for the prevention of accidental release of regulated toxic and flammable substances. There are many similarities between these standards; however, the applicability varies based upon the type and quantity of highly hazardous chemicals on site.

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The OSHA PSM standard contains the following program elements:

The first provision of the standard states that employers shall consult with employees and their representatives on the conduct and development of process hazards analyses (a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals) and on the development of the other elements of the process safety management program. This is fundamental in successful program implementation because employees are key stakeholders. They not only understand their company’s business processes, but can facilitate company compliance with the documentation requirements of the standard if the program is integrated into their business processes.

It is not uncommon to audit a PSM or RMP facility and find that the program documents are located in a binder collecting dust on a shelf. Many companies hire consultants to develop a program on their behalf. This is an effective way to capitalize on past program implementation experience and program templates. However, if the consultant does not have access to the key program stakeholders during the development phase, the result may be a boilerplate program that doesn’t reflect the activities and processes appropriate for the site. Thus, the program does not get effectively implemented and both the operation and its employees are at risk.

Once your process safety management program has been implemented and integrated into your business processes, change management becomes a process that is planned for, and not an afterthought. An effective management of change process ensures that process hazard analyses are conducted during the design phase, thus minimizing costly rework and delays; standard operating and maintenance procedures are developed in advance of starting up; and that pre start-up safety reviews are scheduled into the project as a milestone and not an exercise that occurs when it is identified as a deficiency in your PSM compliance audit.

Process Safety Management in the Headlines

Process safety management program compliance has hit the headlines and is becoming a hot button in the regulatory community. OSHA recently reached an agreement with a large North American oil company which will settle citations and penalties and requires the company to address process safety management plant-wide. “This citation and penalty – nearly double the next largest fine in OSHA history – sends a strong message to all employers about the need to protect workers and to make health and safety a core value,” states Howard M. Radzely, Solicitor of Labor.

The key to a successful program is to involve major stakeholders in the program development phase and ensure that checklists and business processes are not only compliant with regulations, but also integrated into your business processes.

To Learn More about PSM, RMP, & CalARP Compliance Support

If your organization is implementing a change to an applicable process, due for a PHA revalidation, three year compliance audit, or RMP update, EORM provides program management and compliance support services. Our consultants can help you in the development of a high level Compliance Roadmap in addition to supporting various tactical elements of these programs.

For more information about Process Safety Management, please refer to these additional resources:

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