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Managing a Process Safety Program
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 last 30 years. Therefore, we have prepared a series of four posts to do with process safety. This post is the fourth in the series. The posts are:
Managing a Process Safety Program (this one).
The key word in the term ‘Process Safety Management’ is Management. Therefore, it is useful to consider some of the management issues to do with PSM, and the OSHA regulation in particular.
What gets measured gets done
No management program can be effective unless progress is measured against defined, quantitative goals. PSM is no different. The catch is that it can be difficult to measure progress in this area because there are relatively few catastrophic events. Also, many of the management elements are quite subjective, hence they are difficult to measure.
A Process Safety Management system is not something that is created and then handed down by management to their employees and contract workers; it is a program that involves everyone: designers, operators, maintenance technicians, managers and senior executives. The key word is involvement — which is much more than just communication. All managers, employees and contract workers are responsible for the successful implementation of the program.
Management will provide determined and committed leadership, and needs to organize and lead the initial effort. But the employees must be fully involved in the program's implementation and improvement because they are the people who know the most about how a process really operates, and they are the ones who have to execute recommendations and changes. Specialist groups, such as staff organizations and consultants can provide help in specific areas, but process safety is fundamentally a line responsibility.
The implementation of a PSM program requires thoroughness. For example, a company may have a good training program, but one person may have missed part of it because he or she was on vacation. Management needs to make sure that this person is fully trained and that his or her personnel files are updated appropriately.
The elements of process safety have strong interaction with one another — it is not possible to meet the requirements of one of the elements without considering its effect on the others.
The inter-connectedness of the elements can be illustrated by considering the development of an Emergency Response Plan, in which the following sequence of actions — involving seven of the management elements — may occur.
The writing of the Emergency Response Plan (element 12) requires a knowledge of which hazards have to be addressed.
Consequently, a Hazards Analysis (element 3) is required to identify those hazards.
In order to be able to carry out the hazards analysis, information from sources such as P&IDs and MSDS is needed. Much of this information is included in the Process Safety Information (element 2).
Once the Emergency Response Plan has been developed, it will be necessary to Train everyone in its use (element 5).
The Emergency Response Plan has to be Audited on a regular basis (element 13).
During the training process, those being trained will come up with ideas that will improve the quality of the emergency response plan. This Employee Participation (element 1).
After going through the Management of Change step (element 10), these ideas can be used to upgrade the emergency manual.
When considered in isolation, many of the elements appear to be the "most important". For example, Employee Participation is the "most important" because, if the employees do not participate, the process safety program will not function properly. But Management of Change could be considered the "most important" because the root cause of all incidents is uncontrolled change. On the other hand, all of the elements require a solid base of up-to-date, comprehensive information. Therefore Process Safety Information is the "most important". But then it could be argued that Incident Investigation and Root Cause Analysis is what really matters because incidents reveal what is really going on in the organization.
The real point, of course, is that they are all important and necessary, and that they all rely on one another to be effective.
The index of the posts to do with the update to the OSHA process safety standard is provided here.
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