As most are aware if we ever picked fruit of any kind, the easiest fruit to retrieve are those that are hanging low on the vine. Speaking from direct experience, this same analogy applies to regulatory compliance officers; they go after those regulatory infractions that are obvious, the employer has a hard time refuting, and are easy to defend in a court of law. Of course, it can also be said, that if we cannot do the easy things, how could we ever really be expected to fully understand and apply process safety principals at all? Even though there is a lot of truth to this last statement, there are legitimate cases where we can honestly forget, get distracted by other larger issues, and lose track of the smaller things. Some of the low hanging fruit in process safety that can get overlooked or forgotten includes such items as updating the emergency contact person in the RMP, revalidating the PHA every five years, conducting a PSM/RMP compliance audit every three years, addressing action items or recommendations in a timely manner, just to name a few. Each of these items mentioned are easy for a regulatory agency inspector to find, and the regulatory language is plain and simple. Of course, one could argue that completing an action item in a timely manner is “subjective”. However, it is not subjective when we set or fail to set a target date, and nothing has been done to show progress…just crickets! With no documented progress, the timely manner requirement was simply ignored. The items listed here do not represent all the easy or low hanging fruit regarding compliance. The best way to avoid citations and move toward a more robust process safety culture, is understanding where you are through a simple gap analysis. Now, is the best time to see where your gaps are, start addressing identified gaps, and improve process safety along the way.
Low Hanging Fruit