Process Safety Management – 18 Years Later
As you go about the performance of your three year required self-audit (Compliance Audit); look at each element of your program critically and ask yourself, “Is the program current and up to date?”
Written by Charles Jackson, CIH
Within the past two to three years the United States has experienced several industrial catastrophic incidents which have resulted in the loss of life and extensive property damages. A few incidents that come readily to mind (these are not the only ones) include: the sugar refinery incident in Georgia, the BP oil refinery incident, the Kleen Energy incident in Connecticut, and the BP oil rig incident in the Gulf. One may ask the question, “Why have these happened?” The investigations to the incidents that have been completed in all cases conclude that they could have been prevented.
Those of us who were practicing safety and health professionals in the late 1980’s and early 1990’s recall that there were a vast number of catastrophic events that occurred in the 1970s and 1980s. It was those events that led Congress to demand that the regulatory agencies (EPA and OSHA) put regulations and enforcement into effect which would prevent these types of industrial incidents. One major regulation promulgated by OSHA in 1992 was the Process Safety Management Standard (1910.119). This standard set a new bar for safety and health management and discipline for all industrial facilities that came under the standard’s requirements. While OSHA had issued many other performance standards, this standard spelled out 14 specific elements it requires to be met for the “management” of highly hazardous chemical processes.
Following the requirements of the PSM Standard is mandatory for those facilities who meet the requirements spelled out in the standards, mainly the list of chemicals and their threshold quantities. Some industries struggled with coming into compliance with PSM, however many others saw it as a good tool to be used to assist them in the management of non-PSM required processes. Bottom-line, for the past eighteen years we have had the standard in place and it appears to be achieving its designed purpose of preventing industrial catastrophic incidents.
From 1992 up until the past two to three years we have not heard much if any about catastrophic industrial incidents. Have we become complacent and comfortable with our processes? Or has the business economy driven us to only do what is required and no more?
As you go about the performance of your three year required self-audit (Compliance Audit); look at each element of your program critically and ask yourself, “Is the program current and up to date.” This may seem like an unrealistic thing to do since the audit is supposed to catch any deficiencies; but think about when and who developed your program. Are they still there? Do all current affected persons know the details of the program that was developed 18 years ago? Pay special attention to your Management of Change (MOC) element. At this juncture of your PSM Program, MOC is the key that maintains the program and keeps it current and alive. MOC should make sure that all other 13 elements stay updated and current, especially your education and training of all affected persons including contractors.
Consider using some or all of the 14 elements of this management tool for managing other hazardous chemical processes. Some of the recent catastrophic incidents that have occurred may not have been PSM required, however the use of a management tool may have prevented their events. Regardless of PSM or non-PSM, if an industrial catastrophic incident occurs the investigation party will ask to review your management system for the prevention of loss of life and minimization of property damage.
If you would like more information or assistance with your PSM processes, please contact SET Solutions today.