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Elements of Process Safety Management (PSM)
We have been writing a series of posts to do with the proposed changes to the OSHA process safety management standard. (The index of the posts that have been published so far is here.)
Since OSHA has chosen to re-open the standard, it makes sense to consider some of the basics of process safety management (PSM): what it is, what it is meant to achieve, and how it may have changed in the 30 years since OSHA first published their regulation. Therefore, we have prepared a series of four posts to do with process safety. This post is the second in the series. The posts are:
Elements of Process Safety Management (this one),
Managing a Process Safety Program.
Process safety programs are built up of management elements. The OSHA regulation contains the following fourteen elements.
Process Safety Information
Process Hazards Analysis
Prestartup Safety Review
Management of Change
Emergency Planning and Response
The 14 elements in the OSHA standard have limitations. For example,
Employee Participation is too limited. It should include everyone who designs, operates or maintains a process facility — not just employees.
Process Safety Information is also too limited. In order to develop an effective PSM program a foundation of technical information is needed. Only when that information has been evaluated in process hazards analyses can we know if it is “safety information”. There is a circular logic here.
Training and Education are not the same thing. A person can be trained in how to start a pump, for example. He or she needs to be educated so as they know what to do when the pump does not start, or when it does not function as expected.
Prestartup Safety Review should be part of the broader topic of operational readiness.
Mechanical Integrity should be Equipment and Instrumentation Integrity.
Hot Work should cover all types of permitted work, including vessel entry and working with electrical equipment.
Compliance Audits could include assessments that evaluate performance beyond simple compliance.
Trade Secrets are a legal issue that are not generally relevant to the management of a process facility.
Comments such as these demonstrate the need for an update to the standard.
Other organizations, such as the American Petroleum Institute (API) and the American Chemistry Council, have developed their own lists. The one developed by the CCPS (Center for Chemical Process Safety) is shown below, and is the one we use in our Safety Moments.
Process Safety Culture
Hazard Identification and Risk Management
Safe Work Practices
Asset Integrity / Reliability
Training / Performance
Management of Change
Conduct of Operations
Measurement and Metrics
Some large energy and chemical companies develop their own management structure. The following is used by Exxon Mobil (2016).
Management leadership, commitment and accountability
Risk assessment and management
Facilities design and construction
Personnel and training
Operations and maintenance
Management of change
Incident investigation and analysis
Community awareness and emergency preparedness
Operations integrity assessment and improvement
In spite of the differences in detail these programs are generally similar to one another and have the same goals. (Note that none of the newer lists contain the Trade Secrets element, which is more of a legal issue than a technical or management concern.)
If should also be noted that the terminology used can also vary. For example, OSHA uses the term "Prestartup Safety Review" whereas CCPS uses "Operational Readiness". Both terms strive for the same goal: ensure that a facility is safe to start after it has been modified.
The index of the posts to do with the update to the OSHA process safety standard is provided here.
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