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One important aspect of the OSHA PSM standard that we must keep in mind, is that it was developed and promulgated in the early 1990s, and has not really changed any since then, but our industry has changed a lot. However, the same principles of process safety management are just as relevant today as there were over 25 years ago. The 14 elements of the PSM standard constitute the framework of a safety and health management system (SHIMS). As is the case in all effective management systems, the standard contains the continuous improvement model elements; plan, do, check, and act (PDCA). The 14 elements of PSM are the “plan” portion, and when implemented, the “do” portion, achieves risk management or process safety. The “check” portion is the compliance audit element, and the “act” is implementing the recommendations from the compliance audits, incident investigations, and hazard assessments.
Again, how each of the PSM elements are implemented is not defined by the PSM standard, but rather it is left up to the owner of the covered process (performance standard). Therefore,...more
Unfortunately, it is all too common for “good” companies to be lulled into a false sense of security by their performance in personnel safety and health. They may not realize how vulnerable they are to a major incident, until it happens. Subsequent investigations of incidents at these “good” companies has typically shown that there were multiple causal factors, and many were known long before the event occurred. In many cases, the company often assumed systems worked as intended, despite the warning signs. They will find examples of “good” performance and assume they represent the whole, while poor examples are overlooked or soon forgotten, rather than digging deeper to understand what is really happening. Analysis of failure modes and effects should go beyond the equipment, physical, and information technology systems, and must include human and organizational aspects as well. Recognition of the seriousness of consequences and mechanisms of causation lead to a focus on process safety rather than on individual employee(s) performance. In fact, many of the key decisions...more
If you look at Bureau of Labor Statistics (BLS) data across the various industries prior to the promulgation of OSHA-PSM and EPA-RMP regulations, it will show that Oil & Gas, Refining, and Petrochemical industries were much better as an industry than other industrial sectors such as machinery manufacturing, logging, commercial fishing, and food production, from a purely injury and illness standpoint. If we look at the current BLS data for the same industries today, there has not been near the improvement you would expect. There are a lot of reasons that keep us as a process industry, from achieving a paradigm shift in process safety. One reason is that when a team is given more than one objective to achieve, they fail to achieve any of them in the manner we would like or should expect. It does not mean they failed; it just means that they did not achieve at the highest level possible. One of the main reasons is we fail as management to provide a well-defined “management system” that incorporates the teaching and training needed. For example, how many people in our...more
Unfortunately, it is very common for “good” companies to be lulled into a false sense of security by their performance in personnel safety and health goals. They may not realize how vulnerable they are to a major incident until it happens. Subsequent investigations of incidents at these relatively “good” companies have typically show there were multiple causes, and many of these causes were known long before the event occurred. In many cases, people often assume systems work as intended, despite the warning signs. They will find examples of “good” performance and will assume they represent the whole, while poor examples are overlooked or soon forgotten, rather than digging deeper to understand what is really happening.
One of the main causes for a lax process safety culture, is the failure to provide a well-defined “management system” that incorporates the teaching and training that is so crucially needed. For example, how many people in the organization truly understand and have an appreciation of the hazards and risks in the process and can readily recognize them both?...more
How many times have you heard this statement regarding a major release or fire? “If they would have only implemented or adhered to Process Safety Management (PSM) this would not have happened.” Basically, this comment essentially says “we” do not understand the purpose of PSM very well. PSM has nor will it most likely ever, result in “zero” incidents. This is because PSM is not designed to eliminate risks, but rather it is programs and systems that must be in place to “manage” the risks associated with facilities that handle a Highly Hazardous Chemical(s) (HHC). I know that some will say that our goal should be to eliminate incidents and not just manage risk. However, this is not only unrealistic, but most likely not practical either. It would be hard to find anything that we do that does not have associated risk; even living a life in a bubble has inherent risks. So, if we have a realistic view of what we can actually achieve, does it then mean that a facility has failed to manage risk when if they have an incident? Not at all. However, it might be an indication of where...more
Ever wonder how your local grocery store keeps all their produce, meats, drinks, and bread fresh by the time it gets distributed for your weekly grocery run?
Suppliers must refrigerate all food and drinks once the product is made to the time it is delivered to your local HEB or Trader Joe’s. Most people think of freon as a refrigerant, but ammonia is the most commonly used commercial refrigerant in the food and beverage industry today.
Ammonia has replaced the more popular use of freon for two essential reasons:
1. Environmentally friendly
2. Cost Effective
Unlike freon, or otherwise known as chlorofluorocarbons (CFC), ammonia has an ozone depletion rating of 0. Throughout the years, it has been discovered that CFC’s have a huge contribution to greenhouse gases that destroy the ozone layer.
In addition to being earth-friendly, ammonia is extremely cost effective compared to freon. Due to its chemical properties, ammonia requires less piping material and is a more efficient refrigerant resulting in less costs in building an ammonia system and...more
If you work with highly hazardous chemicals at a gas plant or ammonia facility, you may have heard someone mentioning PSM. But what is PSM and why should you care?
PSM stands for Process Safety Management and is a regulation (29 CFR 1910.19) created by OSHA in 1992 due to a rise in catastrophic events.
In 1984, one of the worst incidents in the industry occurred where over 2000 people died due to a chemical release in Bhopal, India. Five years later in 1989, an explosion at a petroleum facility in Pasadena, TX resulted in over a hundred injuries and 23 fatalities. Just a few years later, two deaths occurred from an explosion in Cincinnati, OH in 1990 and eight fatalities due to a chemical release in Sterlington, LA in 1991.
PSM consists of 14 elements intended to help eliminate and/or mitigate the hazards at a facility to ensure a safe workplace for employees.
- Employee Participation
- Process Safety Information
- Process Hazard Analysis
- Operating Procedures
- Pre-Startup Safety...
PSM is an OSHA Program intended to protect workers and the community, while RMP is an EPA Rule intended to protect the environment.
A violation of the OSHA 1910.119 standard is considered serious in nature, and therefore can result in a fine ranging from $13,494 to $134,937 each.
A violation of the EPA section 112(r) of the 1990 Clean Air Act standard can result in a penalty as much as $37,500 per each violation, per day.
Process & Safety Solutions LLC is a Veteran Owned Small Business located in Pearland, TX. Our extensive industry and regulatory knowledge are essential for evaluating PSM and RMP programs. Our lead auditor brings this knowledge and experience as an OSHA PSM compliance specialist who has conducted over 200 Chemical and Refinery National Emphasis Compliance Audits and inspections. Our unique background allows us to conduct compliance evaluations and provide solutions resulting in continuous improvement within process safety with an emphasis on program implementation. Understanding and addressing gaps in your process safety programs lead to...more