When I was growing up in the profession, PSM was the king standard we lived by. Everything we did revolved around our Process Safety Management System. One thing that I continue to find is facility personnel not assigned to the process and contractors working within the covered process “battery limits” and never knowing what they were working next to or in. Almost a 100% bet I will find someone inside the battery limits that has neither been evaluated to be there or trained to be there and I am referring to BOTH in-house personnel and contractors. Now there is no requirement for what I am about to say, so don’t pull your hair out or waste your time digging through the regulations as it is not in there as a “written requirement”, but this is where a “performance-oriented standard” comes into play. We know that both OSHA and EPA require us to “control access” to our covered process(s). I know the standard(s) says “access to facility”, but let’s be real, getting on the facility carries an entirely different risk profile vs that same person(s) getting into and even adjacent to our covered process(s). We can debate the scope of this requirement in another posting, but today I want to point out the need for SIGNS and LABELS around our “covered process”.
In my early days we installed simple and fashionable chains (the Plant Manager was a neat freak! – Gosh I loved working for Claude!) and on each section of cable/chain hung a sign that read: