The poll results indicate a few key points that we need to comprehend as process safety professionals. First, I believe most of us recognize that the PSM regulation outlines a framework for a “management system" designed around the Plan, Do, Check, Act process. All effective management systems possess a crucial element: “buy-in,” which must include employees at all levels. Without this buy-in, the management system is likely to fail; thus, it should be regarded as the most vital aspect. It is not surprising that the initial element of the PSM regulation is employee participation (EP). The regulation mandates that the employer develop a written program for EP. When management documents their strategies for involving employees, it carries significant weight. Unfortunately, in some industries, most EPs are drafted by a consultant without any buy-in from employees, apart from a manager who approves the final document. Typically, interviews with employees reveal the actual level of participation that takes place.

I often discuss safety culture with employers and employees. Many claim we have a strong process safety culture, but evidence shows otherwise. Creating a culture requires taking the time to write a meaningful participation plan with achievable goals and measurable outcomes. It should specify how employees are consulted and communicated with, their responsibilities, and how they will be held accountable regarding process safety. Employee participation is not simply a meeting (though these are important) but rather what occurs in those meetings. Is there teaching, coaching, and mentoring happening, or is it just another paper-pushing exercise? In my many years of experience in the industry and involvement in regulatory compliance, I have yet to find a robust and effective process safety program that does not have an even more robust employee participation program or a culture that embraces process safety as a core value. Do you want to know why your PSI is inaccurate or missing, your PHA is just a repeat of what it has been for the last four cycles, your SOPs do not reflect current operations, or why your operators cannot tell you what the operating limits are, or why your management of change is a mess or ineffective, etc.? It all goes back to participation or buy-in from your organization from top to bottom. Participation and culture take time to build, and most would rather skip it, have a consultant write their programs, and then wonder why we have incidents, poor performance, poor efficiency, and citations. Writing programs is often a waste of time and money if you fail to create the culture that a good management system requires. Build a program with participation as the foundation, and then find ways to improve continuously. There are always many to be found.