It took me several years to realize that a traditional OSH program is NOT a “safety management system.” Like many workplaces, I always had a collection of written occupational safety and health programs placed into binders strategically located throughout the facility. Then, I had a separate PSM (and eventually an RMP) program that was a SEPERATE program. And yes, like many businesses, we claimed this collection of individually written programs as our “safety management system”. And nothing could be further from the truth; a collection of individually written safety programs is not a “safety management system” – they are simply a collection of individually written programs that are put into a single binder (or an electronic folder these days). The binder is literally the ONLY thing holding these programs together! Granted, these written programs are a BIG part of an SMS; however, without several other SMS elements, the typical OSH program is a far cry from a functioning management system.
But for those facilities that are not required to comply with OSHA’s PSM standard or EPA’s Risk Management Plan rule, they rarely have these necessary SMS elements; since they are not an OSHA or EPA requirement outside of PSM/RMP. And this is a significant miss for any business seeking to achieve world-class safety status, as these other supporting elements of the SMS bind all the other elements together.
But why would a business already neck deep into PSM/RMP need to spend the time, money and resources on a 3rd party SMS when the business already has the framework of an SMS within their PSM/RMP program? Why not just utilize the existing PSM/RMP SMS elements to manage the OSH side of the business? Once a business matures in its approach to process safety, the progress will look something like this…
