It is 2024, 32 years after OSHA passed its Process Safety Management of Hazardous Chemicals standard. I am fortunate to have clients who have progressed in their PSM maturity, and we spend a lot of time these days working to get other processes into the PSMS. We start with processes that are not covered because their maximum intended inventory is managed to keep them BELOW the standard’s TQ. In some cases, we apply certain PSMS elements to processes that involve hazardous materials that do not rise to the level of PSM by having a lower risk, but lousy safety performance. Caustic and Acids are two that tend to fall into this category.
But there is one BIG opportunity we can embrace from our friends up north: management owning process safety management. Still today, far too many facilities manage PSM/RMP as a function of the EHS group or the Engineering Group. This approach seems very siloed and goes against the nature of any safety management system. EPA attempted to address this shortcoming of OSHA’s PSM standard by requiring an actual management system (68.15 Management). However, the EPA established the lowest possible expectation by stating that a simple organizational chart could be used to document this SMS. However, I have to give credit to some facilities, as they have used that model and provided very detailed information on which manager owns which elements and spreads the roles and responsibilities across the entire senior management and EHS function.
But I love what Canada did with its CSA Process Safety Management standard (CSA Standard Z767:17) regarding “Management Accountability.” Using some of these requirements, we can assess the level of senior management and, up to the Board of Directors, ownership of Process Safety.