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.
Accountability; Objectives and Goals
- How are Process Safety goals and objectives established throughout the company?
- Are PSM goals and objectives visible to and understood by all workers?
- Are there company objectives that demonstrate the priority of Process Safety compared to other business objectives like production and cost?
- Is accountability for Process Safety clearly identified in roles, responsibilities, and position descriptions?
- Are there appropriate resources available to meet the Process Safety goals and objectives?
- Are there examples of management commitment to Process Safety at all levels of the organization, e.g., directives that state inadvertent loss of process containment situations must be eliminated?
Continuity of Operations
- Is there a policy that makes it clear when operations personnel have the authority to shut down a facility if they believe it is unsafe to operate?
- Are there guidelines or procedures to determine when the facility should be shut down or output reduced for planned or unplanned maintenance or modifications?
- How is the need for spare and redundant equipment identified at the design stages of a project so the facility can reduce the need for a complete shutdown?
- How does the company decide when to segregate parts of a facility so that small sections of the facility can be shut down without shutting down the complete operation?
- Is there a process in place to decide when there is a need to install multiple lines rather than relying on a single stream operation?
Continuity of Systems
- Are resource allocations driven by the process hazards rather than by the economic viability of the process?
- Is there a process to allocate adequate resourcing of supporting job functions or units for each phase of the life cycle of the process?
Continuity of Organization
- Are PSM responsibilities clearly defined as part of position or job descriptions?
- During changes in organizational structure, is there a process in place to ensure that PSM responsibilities are maintained?
- Is accountability for PSM flexible enough to accommodate organizational changes while ensuring that Process Safety tasks are properly assigned and performed throughout the change?
Quality Process
- Do workers understand the scope of issues involved in PSM?
- Does the facility maintain monitoring programs to track the status of Process Safety?
- Are there established goals, targets and key performance indicators (KPI) for measuring Process Safety performance?
- Is there guidance in place to address deviation from this performance?
- Is there a quality assurance system for all aspects of work that includes checking, verification, validation, documentation and configuration management, as appropriate?
Control of Exceptions
- Is there a process in place to assign accountability for the construction, commissioning, and decommissioning of facilities?
- Is there a process in place to deal with situations that are outside the defined elements of existing management systems?
Alternative Methods
- How are accountability and responsibility assigned when practices and procedures are implemented in compliance with performance standards, which identify only desired results without identifying the methods to be used?
- Where more than one method is available for a given task, e.g., for process hazard reviews, what is the established process that ensures that the method selected is effective in completing the task?
Management Accessibility
- Is management available to assist in the decision-making process?
- Is leadership available to resolve conflicting views among safety, engineering, maintenance, production, and business managers?
- Is there a process for conflict resolution on issues that include Process Safety?
Communications
- Does senior management communicate their understanding of Process Safety accountability for their unit and individuals within it?
- Are overlapping responsibilities between individuals/units clearly defined and communicated to ensure that no gaps exist?
Company Expectations
- How does the Board of Directors and the Executive Management Team communicate their expectations regarded Process Safety performance?
- Are the Process Safety goals consistent with other aspects of the organizational vision or master plan?
- Are broad Process Safety goals established by management?
- Is there a process in place to measure Process Safety performance and take any action that may be required?
- Do Process Safety goals address the long-term aims of the company as well as detailed short-term targets?
- Are adequate resources available within or outside the company to achieve Process Safety goals?
- Have key leading and lagging indicators been established to measure Process Safety performance (e.g. Process Safety-related incidents should be included as a lagging metric)?
- Has the organization been benchmarked against others to ensure the best practices are being used?
CLICK HERE to download my WORD document “5.0 Process Safety Leadership (CSA Standard Z767-17)”