This article applies to BOTH facilities practicing process safety and basic OSH. Many of the facilities will declare they have and utilize a Safety Management System (SMS) in their efforts to manage hazards and risks those hazards pose to workers, the environment, and the business. However, I have developed five (5) simple tests to determine if the facility is managing safety/process safety via an SMS.
Please remember that a facility that requires a PSM/RMP management system is REQUIRED to use these tools. Still, over 20+ years of performing PSM/RMP audits, we can conclude that many businesses struggle to meet the management system requirements.
1) Is there a formal and continuous Hazard Identification process? The key here is that it is a constant process, happening regularly, AND involves the hourly workforce who is/are/would be exposed to the hazards being identified.
2) Is there a formal methodology to ANALYZE the hazards identified so that we can properly assess the risks these hazards pose to the workers, environment, and business
3) Is there a formal Risk Assessment Tool used to assign a Risk to each hazard identified so that there is credibility in the management of risks and the business can allocate the proper resources to risk mitigation based on the risk these hazards pose.
4) Is there a formal management system to track corrective actions to CLOSURE from Hazard ID exercises, Audits, Inspections, Incident Investigations, etc.? This formal system can be a simple spreadsheet, but the management system MUST meet the following:
- Items are assigned to Managers; even though they may not do the work, they are the RESPONSIBLE party to see that the time, $, and resources are available to complete the task(s).
- Items are given a “complete by date,” and the “gatekeeper” of this Corrective Action Tracking system monitors for and reports PAST DUE items to Sr. Management
- Management reviews the OPEN and PAST DUE items on a regular schedule. This is usually dictated by the number of items, their risk rankings, and the management group’s performance in consistently closing items on time.
- Items and their status are available to all facility personnel so they can see the status of items.
5) Is there a Management of Change (MOC) process available, AND is it being used to assess the impacts to OS&H and Process Safety for changes to:
- the physical workplace,
- written program, plans, procedures
- staffing changes, BOTH in terms of numbers and experience/quality
For example, a new machine gets added to the production floor…
- Is the machine placed so that it does not obstruct emergency equipment such as EXITS, fire extinguishers, and EW/SSs?
- Is there at least 28″ around the machine for personnel to travel, etc?
- Will this new machine impact the noise levels requiring different HPDs?
- Is the machine guarded properly?
- Were energy control procedures written for the machine’s “servicing/maintenance” tasks?
- Were the interlocks added to a Work Order for annual functional testing?
- Was a training program developed and deployed to train personnel on how to operate this machine?
- Is the electrical supply to the machine in compliance with the ESRWP and state electrical code?
- Is the piping to and from the machine labeled per ASME A13.1?
These are just a few of the items we typically find on newly installed machinery. In fact, we could add just one line item…
Was the New Equipment Hazard Worksheet utilized on this installation?
Yep, many companies will have a “safety checklist” (and some are really good checklists) to use for new installations; however, most fail to use their own checklist!
So having a written SMS sitting on the shelf right next to your compliance programs manual is NOT what we mean when we say we “manage safety via a SMS”.
