PSM: Just another Government Regulation, or Industry Best Practice?
Process Safety Management (PSM) is addressed by OSHA in their standard for highly hazardous chemicals (29 CFR 1910.119). If the standard applies to your company, you likely already know a fair bit about the 14 elements of PSM and how they work together to manage hazards and minimize risk. However, increasingly companies are turning to PSM as a best practice, regardless of whether they are engaged in covered processes. Many companies operating in the energy, chemical and manufacturing industries face similar process safety challenges, regardless of whether OSHA’s PSM standard is applicable to them or not. This quickly becomes clear just by Googling the PSM elements:
Easy enough to look up, these PSM elements are less simple to address effectively and efficiently. Individual companies and even distinct locations will place different levels of emphasis on different elements. However, the challenge facing all companies is determining the best way to ensure safety for their workers, their environment and their community. PSM can be a blueprint to achieve this objective.
To explore this idea, let’s take a look at three of the PSM elements that are typically viewed as high priorities.
For any PSM system to be effective, you need to have the buy-in and participation of all of your employees, at all levels of the organization. This participation encompasses everything from reporting and conducting activities, to monitoring tasks and dashboards and ensuring that tasks are completed on schedule.
Although many people emphasize the importance of management support for company initiatives, it’s equally essential to engage your frontline employees in your company’s approach to process safety management. After all, in many cases it’s your frontline employees who will be required to initiate events and carry out activities, from change requests to near miss reporting and everything in between.
The PSM standard places an appropriate level of importance on employee participation, acknowledging that the ability to influence companywide employee participation in safety initiatives can make or break safety outcomes.
Management of Change (MOC)
By some estimates, 70% of all work-related incidents are the result of poorly managed change. While the exact number may be disputable, examples of poorly managed change with devastating consequences are easy to call to mind. From the 1974 explosion at a chemical plant in Flixborough, England, to India’s Bhopal gas tragedy in 1984, to more recent incidents such as the 2015 Gold King Mine wastewater spill in Colorado, these shocking occurrences could have been prevented or their impacts mitigated if proper change management principles had been followed.
Whether the PSM standard applies to you or not, ensuring that all changes are done in a repeatable manner is both a safe and an efficient business practice. An effective MOC process is characterized by an approach that also ensures all risks are identified and mitigated, all necessary approvals are given, and all related action items are completed. In short, an approach that ensures accountability and traceability. The PSM standard lays out the groundwork to help companies accomplish just that.
While the goal is always to prevent injuries and unsafe conditions, should an incident occur it’s critical to investigate, identify root causes and perform the corrective actions to ensure the incident does not occur again. Of course, this is news to no one, regardless of whether they are covered by OSHA’s PSM standard.
However, following PSM as a best practice approach allows a company to view Incident Investigation as a connected piece of a larger puzzle. If the incident was a result of poorly managed change, ensure that you also review any related MOC’s. Did the incident involve a contractor? How might your training program be modified to address the root cause of the incident and mitigate risk? By emphasizing these connections, the PSM standard can help companies connect the dots required to improve their safety performance.
PSM: Being Efficient & Effective
Whether you are regulated under PSM or you choose to follow it as a best practice, it is important to be both effective (in order to achieve good results) and efficient (to keep associated costs and manpower down).
What this means is that you need not just an effective PSM plan, you also need an efficient way to manage and act on that plan. As we’ve discussed today, the strength of the PSM standard approach lies in the connections between the PSM elements. There will always be a limit to your effectiveness if you address each element as its own, ignoring its ties to the other elements. Similarly, outdated approaches such as Excel and paper-based systems limit efficiency as well.
This is why many companies are turning to Process Safety Management software solutions to manage their PSM processes.
Contact Intelex to speak with one of our PSM / EH&S specialists, to determine if Intelex can deliver the benefits that match with your goals and challenges. Request a Demo today!