Companies who are required to comply with OSHA’s Process Safety Management standard (1910:119) should be on high alert now that inspectors are being encouraged to complete more time-consuming, complex investigations.
The reason? OSHA’s new enforcement weighting system. Prior to this year, OSHA inspectors were measured on one primary metric: the number of inspections they completed. Logically, under this system OSHA inspectors were less likely to spend the time on a complicated and lengthy inspection, when they could complete several more straightforward inspections in the same period of time.
That’s now changing. Under OSHA’s new system each inspection is given a weighting, using a new measure called an Enforcement Unit (EU). Process safety management (PSM) inspections are now being given more weight than nearly all other types of inspections.
Think You’re Ready? Think Again
If OSHA’s PSM standard applies to you, then you’re already very familiar with the 14 elements of process safety management. You’ve trained your workers, and you have systems in place. You’re ready for anything OSHA throws at you, right?
Wrong. That’s because even if you’ve checked off every single box, there is a distinct difference between complying with OSHA’s Process Safety Management standard and being able to demonstrate that compliance to an inspector that shows up at your door.
OSHA’s new weighted enforcement system should be a signal to safety professionals that their PSM system needs to be in a constant state of readiness. What does this mean? It means no shuffling through papers, no missing documents, and no scrambling. Because the more complex the inspection, the more that can go wrong. In the most extreme cases, a process safety management inspection of an oil refinery, for example, can take more than a month to complete. That’s a lot of time for an inspector to spend in your facility.
Inspections Now Prioritizing “Impactful Enforcement Activity”
As we all know, what gets measured gets done. This shift in OSHA’s inspection priorities is bound to be a rude awakening for some companies who are not used to receiving such scrutiny. While inspectors may not have previously been all that well-versed in 29 CFR 1910.119, this new weighting system incentivizes them to become quite familiar conducting process safety management inspections.
“Our inspection metric that gave equal weight to all inspections may have discouraged some offices from committing necessary resources to fully complete more time-consuming, complex investigations,” says David Michaels. OSHA’s chief believes the new system “will encourage the focus of our limited inspection resources on more complex, strategic, and impactful enforcement activity.”
In other words, companies better get their Process Safety Management systems ready for inspection!
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