Canada’s consensus standard for Process Safety Management far surpasses OSHA and EPA’s versions. My favorite upgrade is how senior management has a few of its own sections in the standard. For example:
- Leadership commitment at all levels of an organization is key to achieving excellence in PSM and establishing a process safety culture.
- Management must be visible and must demonstrate this commitment in the activities undertaken.
- Their commitment must be unequivocal and leave no doubt as to their expectations.
ELEMENT 1 – ACCOUNTABILITY: OBJECTIVES AND GOALS
A. INTRODUCTION
Leadership commitment at all levels of an organization is key to achieving excellence in PSM and establishing a process safety culture.
Management must be visible and must demonstrate this commitment in the activities undertaken.
Their commitment must be unequivocal and leave no doubt as to their expectations.
B. REQUIRED ELEMENTS
Each company/business/facility shall:
a) Establish process safety goals and objectives;
b) Ensure that process safety goals and objectives, which address worker, public, environmental, and financial risks, are visible to and understood by all relevant employees;
c) Establish company objectives that demonstrate the priority of process safety compared to other business objectives like production and cost;
d) Clearly identify accountability for process safety in roles, responsibilities, and position descriptions;
e) Ensure that appropriate resources are available to meet the process safety goals and objectives; and
f) Identify expected results that demonstrate management commitment to process safety at all levels of the organization (e.g. a directive that states uncontrolled process fires must be eliminated).
1.1 Continuity of operations
Each business/facility shall establish:
a) A policy that makes it clear when operations personnel have the authority to shut down operational units or a facility if they are concerned that it may be unsafe to operate;
b) Procedures or guidelines to help personnel determine when operational units or the facility should be shut down or output should be reduced for planned or unplanned maintenance or modifications;
c) A system to identify the need for spare and redundant equipment at the design stages of a project so the facility can reduce the need for a complete shutdown;
d) A system to identify when to segregate parts of a facility so that small sections of the facility can be shut down without shutting down the complete operation; and
e) A system to identify when there is a need to install multiple lines rather than rely on single-stream operation.
1.2 Continuity of systems
Each business/facility shall establish a system to:
a) Ensure that resources are allocated based on the process hazards and risks rather than just by the economic viability of the process; and
b) Allocate adequate resourcing of supporting job functions or units for each phase of the life cycle of the process.
1.3 Continuity of organization
Each business/facility shall:
a) Clearly define PSM responsibilities as part of a position or job descriptions;
b) Establish a system to ensure that PSM responsibilities are maintained during changes in the organizational structure; and
c) Ensure accountability for PSM is flexible enough to accommodate organizational changes while ensuring that process safety tasks are properly assigned and performed throughout the change.
1.4 Quality process
Each business/facility shall:
a) Ensure that employees understand the scope of issues involved in PSM;
b) Maintain monitoring programs to track the status of process safety;
c) Establish goals, targets and key performance indicators (KPI) for measuring process safety performance;
d) Ensure that guidance is in place to address deviation from this performance; and
e) Establish a quality assurance system for all aspects of work that includes checking, verification, validation, documentation and configuration management, as appropriate.
1.5 Control of exceptions
Each business/facility shall ensure a system is in place to deal with situations that are outside the defined elements of the existing management systems, and to manage exceptions with appropriate controls, by assigning accountability to qualified personnel, in the following areas:
a) Engineering designs;
b) Construction, commissioning and decommissioning of facilities;
c) Operating procedures;
d) Maintenance practices and procedures;
e) Purchasing practices and procedures; and
f) Qualifications of operating personnel.
1.6 Alternative methods
Each business/facility shall:
a) Establish a system to ensure accountability and responsibility are assigned when practices and procedures are implemented in compliance with performance standards. (Performance-based standards are those which identify desired outcomes without specifying the methods to be used.); and
b) Establish a system to ensure, in an instance where more than one method is available for a given task (e.g. process hazard reviews), the method selected is effective in completing the task.
1.7 Management accessibility
Each business/facility shall:
a) Establish a system to ensure management is available to assist in the decision-making process; and
b) Ensure leadership is available to resolve conflicting views among safety, engineering, maintenance, production and business managers.
1.8 Communications
Each business/facility shall ensure:
a) Senior management communicates their understanding of process safety accountability for their area of responsibility and individuals within it; and
b) Overlapping responsibilities between individuals/areas are clearly defined and communicated so that no gaps or conflicts exist.
1.9 Company expectations
Each company shall ensure:
a) That the Board of Directors and the executive management team communicate their expectations regarding process safety performance;
b) That the process safety goals are consistent with other aspects of the organizational vision or strategic plan;
c) Broad process safety goals are established by management;
d) A system is in place to measure process safety performance and take the required action;
e) Process safety goals address the long-term aims of the company as well as detailed short-term targets; and
f) Adequate resources are available to achieve the process safety goals.