Having an effective Process Safety Management (PSM) program is more than just a compliance issue. Yes, Federal and State agencies continue to conduct OSHA PSM inspections. However, not giving your PSM program the attention it deserves could result in a catastrophe that the Standard is designed to help prevent. Even if a catastrophe is avoided, a near-miss could go unrecognized. Why is that a big deal? Because maybe you were just lucky and luck is no way to run a safety program.
These common PSM program deficiencies are indicators that your program is not being properly managed:
- Lack of Proper PSM training
PSM requires that personnel involved with the operation and maintenance of the covered process receive initial training as well as refresher training every three years.
- Outdated Process Safety Information (PSI)
Many times, facilities have made changes to the covered process without updating this documentation, including: safety relief systems, inventory, ventilation calculations, “Field verified” piping and instrumentation drawings (P&IDs). When the PSI package is not kept up-to-date, it is an indication the program is not being given the attention that it requires, that is to say, there may be serious concerns about the effectiveness of the program.
- Previous Process Hazard Analysis (PHA) Issues
Outstanding PHA recommendations that have not been addressed or properly closed out. This is an indicator one is just “going through the motions.”
- Vague Standard Operating Procedures (SOPs)
Those that are generic in nature, not equipment specific and have not been reviewed/certified annually as required by the OSHA Standard.
- Improper Management of Change (MOC) Documentation
Due to schedule issues, sometimes an MOC is completed after the equipment has been installed and is operational. MOC procedures and the resulting documentation must be fully completed and signed off by the authorizing personnel before startup of the equipment. Similarly, MOCs are many times forgotten when completing changes to Operating Procedures. MOCs are required for any change affecting how you do something (i.e., adding steps to the start-up process of a piece of equipment).
- Gaps in Audit Frequency
Increased workload, staff turnover, etc. can result in audits not being conducted every three years as required by the PSM Standard. Or action items that were generated from the previous audit may not been closed out in time for the next audit cycle.
- Improper or Unorganized Documentation
Even the most rigorous program can have gaps in documentation. However, these should not be common, nor an excuse. Documentation of PSM-related activity should always be kept current. Remember the adage, “if there is no record, it didn’t happen.” In preparation for the audit (the key word here is “preparation”), ensure all written documentation is up-to-date and filed in a format that is easily accessible to the auditor.
Take note of these program deficiencies, before it’s too late.