Update to OSHA’s Process Safety Management Regulation. Part 26: Review of PSM Management Systems

The material in this series of posts has been incorporated into the book The OSHA Process Safety Standard: The 30-Year Update.

---

OSHA’s process safety regulation does not actually require companies to review their management systems. That they should do so is, of course, a sensible requirement. Indeed, all management systems need to be reviewed on a regular basis. The audit process that was discussed in the previous chapter (paragraph (o) of the regulation) will not only identify gaps in performance, but it can help identify ways in which the management process itself could be improved. Nevertheless, a different process for evaluating and improving management systems is needed. Audits measure performance against an existing standard; management reviews evaluate the management systems that are being used to meet regulatory requirements.

When conducting a PSM review there are four questions to ask.

1. What is our current status?

2. Where are we most vulnerable?

3. How are we progressing?

4. How do we compare to others?  

None of these questions fall under the purview of the normal audit process.

The Regulation

OSHA did not assign this update to any particular element. In this post it is placed in the Application category.