Ask 10 safety professionals what an effective Process Safety Management (PSM) program looks like, and you’ll most likely get 10 different answers.
Such is the complexity and nuance associated with PSM — and OSHA’s requirements around the handling of highly hazardous chemicals — that it’s rare for consensus to form over one or two answers.
That’s not to say we don’t understand what an effective PSM program looks like. It simply means that there are many avenues a site can take to meet OSHA’s PSM requirements and maintain a program that goes above and beyond in protecting the workforce.
Let’s assume that we all know and understand the 14 process safety elements that form the backbone of OSHA’s PSM standard — 29 CFR 1910.119. Countless safety trainers and organizations have developed and provided intensive training and best practice-sharing since the standard was published in 1992.
Yet, the first question many of us in the trade association world be asked when speaking about PSM is whether or not your company or site is subject to PSM requirements.
Such is the mystery behind PSM that, even with the voluminous knowledge and real-world implementation examples we have, there’s still some confusion around who exactly falls under PSM requirements.
The short answer: Anyone dealing in hazardous chemicals (I should note here that as a practice, many of PSM’s 14 elements are broadly applicable across industries and can be used as best practices for those who don’t fall under 1910.119.).
The long answer: Anyone dealing in hazardous chemicals where workers are present, where flammable gases and liquids are being handled in large quantities, manufacturing facilities that deal in highly hazardous chemicals and most every chemical or petrochemical facility except O&G well drillers.
Or most readers of this fine publication. Once applicability is established, then the real questions commence. What are the most important elements? How do I know if my PSM program is effective? Does PSM apply to onsite contractors? How do I get workers to understand the elements and our PSM requirements?
And, of course, the biggest question of all: What are the most difficult elements to implement and how do I master Management of Change (MOC) processes?
When planning for the first VPPPA PSM Best Practices Training Summit in 2023, we asked that first question to our members — What are your PSM pain points? The overwhelming consensus led to the second question — How in the heck do I implement an effective MOC process?
Implementing and maintaining successful MOC programs first requires a detailed understanding of the complex written procedures surrounding any changes to chemical handling and processing, equipment and technology used, facility processes and more. What is the change’s impact on workers’ safety and health? What is the basis for the change? Who is involved in the decision-making and authorization chain? How does this affect SOPs? How long will implementation take? What new and updated training will be required?
With so many components involved, it’s no wonder that the majority of questions we received at our PSM Summits, and event surveys, centered around MOC best practices. It’s why the best training around MOC involves commiserating with fellow PSM’ers — while we share the same struggles, we also have our own success stories that, when shared together, help us with "R&D" (ripoff & deployment) of these successes to form effective overall programs, especially when it comes to training.
PSM is an effective tool in our EHS&S arsenal — not just for those who fall under OSHA’s requirements for it, but for any company or site seeking to engage in continuous improvement. Like VPP, PSM has many elements that can be applied beyond the traditional industries which fall under the standard — if we understand how each element is connected and its application to the broader safety picture.
When it comes to the mysteries of PSM, we truly are not alone. And that’s a good thing because sharing our pain — and successes — means continuous improvement toward health and safety excellence.
For more information, visit vpppa.org.
